https://www.taxtmi.com/caselaws?id=785234 Disallowance under the concept of initial assessment year was considered only for determining the duration of deduction and not as a basis to deny setting off of notional carried forward losses; the appellate authority applied CBDT Circular No.1/2016 and a precedent considering the assessees choice of initial assessment year and dismissed Revenue grounds accordingly. On disallowance under section 14A read with Rule 8D, the principle affirmed is that such disallowance cannot exceed the amount of exempt income, consistent with established precedents, and the excess disallowance was not sustained. en-us Fri, 16 Jan 2026 00:00:00 +0530 Tue, 20 Jan 2026 06:31:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785234 Disallowance under the concept of initial assessment year was considered only for determining the duration of deduction and not as a basis to deny setting off of notional carried forward losses; the appellate authority applied CBDT Circular No.1/2016 and a precedent considering the assessees choice of initial assessment year and dismissed Revenue grounds accordingly. On disallowance under section 14A read with Rule 8D, the principle affirmed is that such disallowance cannot exceed the amount of exempt income, consistent with established precedents, and the excess disallowance was not sustained. Case-Laws Income Tax Fri, 16 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785234