https://www.taxtmi.com/caselaws?id=465377 Disallowance under s.14A r.w. Rule 8D was held mandatory where exempt dividend arose from shares held as investments, and the "dominant purpose" of acquiring shares (including for controlling interest) was irrelevant; s.14A applied. Expenditure incurred for planning strategic investments (e.g., foreign travel and related costs) was treated as direct expenditure under Rule 8D(2)(i) in the absence of proof of any other purpose, and was sustained as includible. However, interest was held not disallowable under Rule 8D(2)(i) and was directed to be excluded. Related-party professional service payments and depreciation were held outside Rule 8D(2)(i) and deleted. Disallowance under Rule 8D(2)(ii) was deleted as mixed funds had already been proportionately considered. Under Rule 8D(2)(iii), computation was directed to be restricted to investments actually yielding exempt income. en-us Fri, 20 Dec 2024 00:00:00 +0530 Thu, 18 Dec 2025 22:30:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465377 Disallowance under s.14A r.w. Rule 8D was held mandatory where exempt dividend arose from shares held as investments, and the "dominant purpose" of acquiring shares (including for controlling interest) was irrelevant; s.14A applied. Expenditure incurred for planning strategic investments (e.g., foreign travel and related costs) was treated as direct expenditure under Rule 8D(2)(i) in the absence of proof of any other purpose, and was sustained as includible. However, interest was held not disallowable under Rule 8D(2)(i) and was directed to be excluded. Related-party professional service payments and depreciation were held outside Rule 8D(2)(i) and deleted. Disallowance under Rule 8D(2)(ii) was deleted as mixed funds had already been proportionately considered. Under Rule 8D(2)(iii), computation was directed to be restricted to investments actually yielding exempt income. Case-Laws Income Tax Fri, 20 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465377