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    <title>2026 (3) TMI 1260 - ITAT MUMBAI</title>
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    <description>Section 14A disallowance under Rule 8D requires the Assessing Officer to record objective satisfaction, based on the accounts, that the assessee&#039;s suo motu claim is incorrect; on the facts, the additional disallowance was deleted. The rental-income addition required verification of ownership or holding of land or building and any actual rental receipts, so the matter was remanded to the Assessing Officer for fresh adjudication. Interest under sections 234B and 234C was treated as consequential and was not disturbed on the recorded facts. The challenge to initiation of penalty proceedings under section 270A was held premature because no penalty order was under challenge.</description>
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    <pubDate>Fri, 20 Feb 2026 00:00:00 +0530</pubDate>
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      <title>2026 (3) TMI 1260 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=788505</link>
      <description>Section 14A disallowance under Rule 8D requires the Assessing Officer to record objective satisfaction, based on the accounts, that the assessee&#039;s suo motu claim is incorrect; on the facts, the additional disallowance was deleted. The rental-income addition required verification of ownership or holding of land or building and any actual rental receipts, so the matter was remanded to the Assessing Officer for fresh adjudication. Interest under sections 234B and 234C was treated as consequential and was not disturbed on the recorded facts. The challenge to initiation of penalty proceedings under section 270A was held premature because no penalty order was under challenge.</description>
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      <pubDate>Fri, 20 Feb 2026 00:00:00 +0530</pubDate>
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