https://www.taxtmi.com/caselaws?id=465804 Disallowance under s.14A r.w. Rule 8D was examined where the taxpayer had made a suo motu disallowance towards exempt income. The Tribunal held that the AO must record satisfaction, having regard to the accounts, that the taxpayer's claim is incorrect before invoking Rule 8D, and a mechanical application of Rule 8D is impermissible; precedent from HC decisions was followed to hold that Rule 8D applies only after such dissatisfaction is recorded. The Tribunal also accepted that the taxpayer had identified and disallowed expenses attributable to an in-house treasury function, and remand was unwarranted. Consequently, the s.14A r.w. Rule 8D disallowance was deleted and the appeal was allowed. en-us Thu, 27 Jun 2024 00:00:00 +0530 Fri, 09 Jan 2026 19:03:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465804 Disallowance under s.14A r.w. Rule 8D was examined where the taxpayer had made a suo motu disallowance towards exempt income. The Tribunal held that the AO must record satisfaction, having regard to the accounts, that the taxpayer's claim is incorrect before invoking Rule 8D, and a mechanical application of Rule 8D is impermissible; precedent from HC decisions was followed to hold that Rule 8D applies only after such dissatisfaction is recorded. The Tribunal also accepted that the taxpayer had identified and disallowed expenses attributable to an in-house treasury function, and remand was unwarranted. Consequently, the s.14A r.w. Rule 8D disallowance was deleted and the appeal was allowed. Case-Laws Income Tax Thu, 27 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465804