https://www.taxtmi.com/caselaws?id=466846 The dispute concerns invocation of disallowance for exempt or non-taxable income using the apportionment formula and whether the Assessing Officer recorded the requisite satisfaction before applying the formula; the tribunal applied the principle that a reasoned satisfaction is necessary and found the coordinate-bench decision on identical facts controlling. The tribunal also noted the assessee had, in effect, made a suo-motu disallowance by debiting expenses to capital account rather than the profit and loss account. Applying the precedent, the additions under the apportionment rule were deleted and the appeal allowed for the assessee. en-us Tue, 25 Feb 2025 00:00:00 +0530 Sun, 22 Feb 2026 22:48:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466846 The dispute concerns invocation of disallowance for exempt or non-taxable income using the apportionment formula and whether the Assessing Officer recorded the requisite satisfaction before applying the formula; the tribunal applied the principle that a reasoned satisfaction is necessary and found the coordinate-bench decision on identical facts controlling. The tribunal also noted the assessee had, in effect, made a suo-motu disallowance by debiting expenses to capital account rather than the profit and loss account. Applying the precedent, the additions under the apportionment rule were deleted and the appeal allowed for the assessee. Case-Laws Income Tax Tue, 25 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466846