https://www.taxtmi.com/caselaws?id=466267 Disallowance under section 14A was contested on grounds that the assessing officer failed to record specific reasons for rejecting the assessee's detailed apportionment of expenditure for earning exempt income. The AO reproduced submissions and invoked Rule 8D but did not identify defects in the assessee's working or explain why the applied ratios were unacceptable; consequently the assessing officer's recorded dissatisfaction did not meet the requirement of reasoned recording and was rightly rejected by the appellate authority. However, the appellate authority's application of an adhoc 1% disallowance to enhance taxability was legally unsustainable and was set aside in favour of the assessee. en-us Mon, 03 Jan 2022 00:00:00 +0530 Sat, 31 Jan 2026 11:47:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466267 Disallowance under section 14A was contested on grounds that the assessing officer failed to record specific reasons for rejecting the assessee's detailed apportionment of expenditure for earning exempt income. The AO reproduced submissions and invoked Rule 8D but did not identify defects in the assessee's working or explain why the applied ratios were unacceptable; consequently the assessing officer's recorded dissatisfaction did not meet the requirement of reasoned recording and was rightly rejected by the appellate authority. However, the appellate authority's application of an adhoc 1% disallowance to enhance taxability was legally unsustainable and was set aside in favour of the assessee. Case-Laws Income Tax Mon, 03 Jan 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466267