https://www.taxtmi.com/caselaws?id=466150 Disallowance under Section 14A and invocation of Rule 8D were upheld as not arbitrary because the assessing officer recorded dissatisfaction and relied on direct and indirect costs; AO is directed to exclude growth-fund investments and investments not yielding exempt income when computing opening/closing investment values and to restrict disallowance to the Rule 8D computation or exempt income, whichever is lower. Claim for set off of business loss and unabsorbed depreciation arising from a demerged undertaking must be adjudicated under the provision governing demerger set off (to be considered under the appropriate demerger provision) and the AO is directed to verify and grant TDS and advance tax credits after due verification; interest under the provision for interest on shortfall is to be recomputed consequentially. en-us Thu, 12 Dec 2024 00:00:00 +0530 Tue, 27 Jan 2026 19:03:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466150 Disallowance under Section 14A and invocation of Rule 8D were upheld as not arbitrary because the assessing officer recorded dissatisfaction and relied on direct and indirect costs; AO is directed to exclude growth-fund investments and investments not yielding exempt income when computing opening/closing investment values and to restrict disallowance to the Rule 8D computation or exempt income, whichever is lower. Claim for set off of business loss and unabsorbed depreciation arising from a demerged undertaking must be adjudicated under the provision governing demerger set off (to be considered under the appropriate demerger provision) and the AO is directed to verify and grant TDS and advance tax credits after due verification; interest under the provision for interest on shortfall is to be recomputed consequentially. Case-Laws Income Tax Thu, 12 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466150