https://www.taxtmi.com/caselaws?id=465588 Disallowance under s.14A r/w Rule 8D was challenged on the ground that exempt-income yielding investments were old, brought forward from earlier years, and funded from own surplus without any borrowed funds. The Tribunal held that, in the absence of any new investments during the relevant year and with sufficient own funds, no expenditure could be presumed to have been incurred in relation to exempt income. It further held that the AO failed to record the mandatory satisfaction under s.14A(2) regarding incorrectness of the assessee's claim, and mere mechanical application of Rule 8D was impermissible; jurisdictional HC authority requiring satisfaction based on credible material was followed. The revenue's appeal was dismissed and the s.14A disallowance was deleted. en-us Tue, 09 Sep 2025 00:00:00 +0530 Wed, 31 Dec 2025 20:13:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465588 Disallowance under s.14A r/w Rule 8D was challenged on the ground that exempt-income yielding investments were old, brought forward from earlier years, and funded from own surplus without any borrowed funds. The Tribunal held that, in the absence of any new investments during the relevant year and with sufficient own funds, no expenditure could be presumed to have been incurred in relation to exempt income. It further held that the AO failed to record the mandatory satisfaction under s.14A(2) regarding incorrectness of the assessee's claim, and mere mechanical application of Rule 8D was impermissible; jurisdictional HC authority requiring satisfaction based on credible material was followed. The revenue's appeal was dismissed and the s.14A disallowance was deleted. Case-Laws Income Tax Tue, 09 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465588