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    <title>Appeal succeeds: Rule 8D disallowance invalid without 14A(2) satisfaction; business, repair expenses allowed as revenue under 37(1)</title>
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    <description>ITAT allowed the assessee&#039;s appeal substantially. The disallowance u/s 14A r.w.r. 8D was largely deleted, holding that AO failed to record the mandatory satisfaction u/s 14A(2), rendering application of Rule 8D jurisdictionally invalid; the assessee&#039;s suo motu disallowance was accepted, with Rule 8D(2)(i) and 8D(2)(ii) disallowances deleted, and Rule 8D(2)(iii) confined to investments actually yielding exempt income. Disallowances of professional fees to a group foundation and expenses of the UK branch/guest house were held revenue in nature and allowable u/s 37(1), including refurbishment expenses treated as repairs. However, payment for installation of a new pump system was held capital in nature, with depreciation allowable.</description>
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    <pubDate>Fri, 12 Dec 2025 08:55:17 +0530</pubDate>
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      <title>Appeal succeeds: Rule 8D disallowance invalid without 14A(2) satisfaction; business, repair expenses allowed as revenue under 37(1)</title>
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      <description>ITAT allowed the assessee&#039;s appeal substantially. The disallowance u/s 14A r.w.r. 8D was largely deleted, holding that AO failed to record the mandatory satisfaction u/s 14A(2), rendering application of Rule 8D jurisdictionally invalid; the assessee&#039;s suo motu disallowance was accepted, with Rule 8D(2)(i) and 8D(2)(ii) disallowances deleted, and Rule 8D(2)(iii) confined to investments actually yielding exempt income. Disallowances of professional fees to a group foundation and expenses of the UK branch/guest house were held revenue in nature and allowable u/s 37(1), including refurbishment expenses treated as repairs. However, payment for installation of a new pump system was held capital in nature, with depreciation allowable.</description>
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      <pubDate>Fri, 12 Dec 2025 08:55:17 +0530</pubDate>
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