https://www.taxtmi.com/caselaws?id=783492 ITAT Mumbai allowed assessee's appeal against disallowance u/s 14A r.w.r. 8D. The assessee had made a suo motu disallowance in its return. The AO, without recording objective dissatisfaction as mandated by s.14A(2), rejected the assessee's computation with a bare observation that the disallowance was low and directly applied Rule 8D. ITAT held that Rule 8D is not automatic and can be invoked only after the AO, having regard to the accounts, records clear satisfaction that the assessee's claim is incorrect. In absence of such satisfaction, the additional disallowance was held bad in law, and the disallowance was restricted to the assessee's suo motu amount. en-us Thu, 11 Dec 2025 00:00:00 +0530 Wed, 17 Dec 2025 08:28:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783492 ITAT Mumbai allowed assessee's appeal against disallowance u/s 14A r.w.r. 8D. The assessee had made a suo motu disallowance in its return. The AO, without recording objective dissatisfaction as mandated by s.14A(2), rejected the assessee's computation with a bare observation that the disallowance was low and directly applied Rule 8D. ITAT held that Rule 8D is not automatic and can be invoked only after the AO, having regard to the accounts, records clear satisfaction that the assessee's claim is incorrect. In absence of such satisfaction, the additional disallowance was held bad in law, and the disallowance was restricted to the assessee's suo motu amount. Case-Laws Income Tax Thu, 11 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783492