https://www.taxtmi.com/highlights?id=95123 Disallowance under s.14A r/w r.8D was examined where the taxpayer had made a suo motu disallowance against exempt income. Since r.8D is not automatic, the AO could invoke it only after examining the taxpayer's accounts and recording satisfaction under s.14A(2) that the taxpayer's claim was incorrect; a mere remark that the disallowance was "very low" did not meet this statutory requirement. Applying this mandatory satisfaction test, as reiterated in Maxopp, the r.8D-based incremental disallowance was held bad in law and deleted, restricting disallowance to the taxpayer's suo motu amount; the appeal was allowed. - ITAT en-us Wed, 17 Dec 2025 16:12:43 +0530 Wed, 17 Dec 2025 16:12:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=95123 Disallowance under s.14A r/w r.8D was examined where the taxpayer had made a suo motu disallowance against exempt income. Since r.8D is not automatic, the AO could invoke it only after examining the taxpayer's accounts and recording satisfaction under s.14A(2) that the taxpayer's claim was incorrect; a mere remark that the disallowance was "very low" did not meet this statutory requirement. Applying this mandatory satisfaction test, as reiterated in Maxopp, the r.8D-based incremental disallowance was held bad in law and deleted, restricting disallowance to the taxpayer's suo motu amount; the appeal was allowed. - ITAT Highlights Income Tax Wed, 17 Dec 2025 16:12:43 +0530 https://www.taxtmi.com/highlights?id=95123