https://www.taxtmi.com/caselaws?id=784790 Where exempt dividend income was earned, disallowance under s.14A r.w. Rule 8D(2)(ii) was held impermissible because the taxpayer demonstrated availability of sufficient own funds for investments; the interest component was deleted. Disallowance under Rule 8D(2)(iii) was held to require the AO's objective satisfaction, absent on record; recomputation as directed by CIT(A) was sustained. Sales tax and power subsidies could not be adjusted while computing book profit u/s 115JB in view of the limited scope of MAT scrutiny; the taxpayer's challenge failed. On characterisation, subsidies aimed at State industrial development were treated as capital receipts; Revenue's ground was dismissed. Additional depreciation u/s 32(1)(iia) was allowed in favour of the taxpayer. Provision for doubtful debts was treated as actual write-off, allowable u/s 36(1)(vii), and not addable u/s 115JB; Revenue's grounds failed. Long-term capital loss of an amalgamating entity was allowed to be carried forward pursuant to the HC-approved scheme; Revenue's appeal was dismissed. en-us Wed, 31 Dec 2025 00:00:00 +0530 Mon, 12 Jan 2026 09:31:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784790 Where exempt dividend income was earned, disallowance under s.14A r.w. Rule 8D(2)(ii) was held impermissible because the taxpayer demonstrated availability of sufficient own funds for investments; the interest component was deleted. Disallowance under Rule 8D(2)(iii) was held to require the AO's objective satisfaction, absent on record; recomputation as directed by CIT(A) was sustained. Sales tax and power subsidies could not be adjusted while computing book profit u/s 115JB in view of the limited scope of MAT scrutiny; the taxpayer's challenge failed. On characterisation, subsidies aimed at State industrial development were treated as capital receipts; Revenue's ground was dismissed. Additional depreciation u/s 32(1)(iia) was allowed in favour of the taxpayer. Provision for doubtful debts was treated as actual write-off, allowable u/s 36(1)(vii), and not addable u/s 115JB; Revenue's grounds failed. Long-term capital loss of an amalgamating entity was allowed to be carried forward pursuant to the HC-approved scheme; Revenue's appeal was dismissed. Case-Laws Income Tax Wed, 31 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784790