https://www.taxtmi.com/caselaws?id=780577 ITAT DELHI-AT allowed the appeal and deleted the AO's disallowance under s.14A read with Rule 8D. The tribunal found the AO's recorded "satisfaction" to be general and unsupported by specific facts, and held that Rule 8D applies only when AO records justified dissatisfaction. No direct interest or expenditure attributable to exempt income was identified, investments were made from the assessee's own funds, and the assessee had already made a suo-moto disallowance. Consequently the AO's artificial indirect disallowance (including presumed interest) was disallowed; only administrative expenditure could, in principle, be considered. en-us Thu, 30 Oct 2025 00:00:00 +0530 Sat, 01 Nov 2025 08:17:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780577 ITAT DELHI-AT allowed the appeal and deleted the AO's disallowance under s.14A read with Rule 8D. The tribunal found the AO's recorded "satisfaction" to be general and unsupported by specific facts, and held that Rule 8D applies only when AO records justified dissatisfaction. No direct interest or expenditure attributable to exempt income was identified, investments were made from the assessee's own funds, and the assessee had already made a suo-moto disallowance. Consequently the AO's artificial indirect disallowance (including presumed interest) was disallowed; only administrative expenditure could, in principle, be considered. Case-Laws Income Tax Thu, 30 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780577