https://www.taxtmi.com/caselaws?id=467334 Whether the proviso to Rule 8D limits a notional disallowance under section 14A is addressed: the proviso functions as a cap preventing the standard-formula disallowance from exceeding the assessee's total actual expenditure, and is treated as curative in operation so as to apply to the assessment year in question; applying that principle the computed notional disallowance (Rs. 1,40,28,010) is restricted to the assessee's total recorded expenditure (Rs. 4,47,278), inclusive of the assessee's suo moto reduction, resulting in a capped disallowance equal to the actual expenditure. en-us Fri, 21 Feb 2025 00:00:00 +0530 Sat, 14 Mar 2026 18:48:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467334 Whether the proviso to Rule 8D limits a notional disallowance under section 14A is addressed: the proviso functions as a cap preventing the standard-formula disallowance from exceeding the assessee's total actual expenditure, and is treated as curative in operation so as to apply to the assessment year in question; applying that principle the computed notional disallowance (Rs. 1,40,28,010) is restricted to the assessee's total recorded expenditure (Rs. 4,47,278), inclusive of the assessee's suo moto reduction, resulting in a capped disallowance equal to the actual expenditure. Case-Laws Income Tax Fri, 21 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467334