https://www.taxtmi.com/caselaws?id=466820 Disallowance under Section 14A and Rule 8D was examined where the assessee had debited investment-related expenses to capital account and did not claim them against taxable income; the legal principle applied is that Rule 8D may not be mechanically invoked without the Assessing Officer recording satisfaction under the statute when the assessee has made suo motu allocations. On the facts, accounts showed no deductible claim for exempt income and no finding that allocations were incorrect; the mechanical application of Rule 8D to add the contested amount lacked statutory satisfaction and account support, and the disallowance was deleted. en-us Tue, 24 Jan 2023 00:00:00 +0530 Thu, 19 Feb 2026 17:08:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466820 Disallowance under Section 14A and Rule 8D was examined where the assessee had debited investment-related expenses to capital account and did not claim them against taxable income; the legal principle applied is that Rule 8D may not be mechanically invoked without the Assessing Officer recording satisfaction under the statute when the assessee has made suo motu allocations. On the facts, accounts showed no deductible claim for exempt income and no finding that allocations were incorrect; the mechanical application of Rule 8D to add the contested amount lacked statutory satisfaction and account support, and the disallowance was deleted. Case-Laws Income Tax Tue, 24 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466820