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    <title>Revenue appeal dismissed; assessee&#039;s claim under section 14A read with r.w.r. 8D upheld due to AO&#039;s procedural defects</title>
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    <description>ITAT dismissed the revenue&#039;s appeal and upheld the CIT(A)&#039;s allowance of the assessee&#039;s claim under section 14A read with r.w.r. 8D. The Tribunal found the AO&#039;s suo-moto disallowance unreasonable and procedurally defective because no contemporaneous satisfaction was recorded to justify overriding the assessee&#039;s self-disallowance, and the AO failed to segregate investments yielding exempt income. The AO&#039;s computation, which exceeded total P&amp;L expenses and ignored the assessee&#039;s working confined to investments producing exempt income, was held to lack logical basis and factual appreciation. Consequently, the excess disallowance imposed by the AO was deleted and the revenue&#039;s appeal dismissed.</description>
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    <pubDate>Wed, 19 Nov 2025 08:52:42 +0530</pubDate>
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      <title>Revenue appeal dismissed; assessee&#039;s claim under section 14A read with r.w.r. 8D upheld due to AO&#039;s procedural defects</title>
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      <description>ITAT dismissed the revenue&#039;s appeal and upheld the CIT(A)&#039;s allowance of the assessee&#039;s claim under section 14A read with r.w.r. 8D. The Tribunal found the AO&#039;s suo-moto disallowance unreasonable and procedurally defective because no contemporaneous satisfaction was recorded to justify overriding the assessee&#039;s self-disallowance, and the AO failed to segregate investments yielding exempt income. The AO&#039;s computation, which exceeded total P&amp;L expenses and ignored the assessee&#039;s working confined to investments producing exempt income, was held to lack logical basis and factual appreciation. Consequently, the excess disallowance imposed by the AO was deleted and the revenue&#039;s appeal dismissed.</description>
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      <pubDate>Wed, 19 Nov 2025 08:52:42 +0530</pubDate>
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