https://www.taxtmi.com/caselaws?id=792137 Rule 8D disallowance under section 14A was not justified where the assessee had made a scientific suo motu computation and the Assessing Officer recorded no proper dissatisfaction. Interest on capital work in progress was also disallowed only where borrowed funds were used; if own funds exceeded the investment, no interest disallowance arose. Gains from sale of shares and units were treated as capital gains where the investments were strategic, long-term, and separately maintained from trading activity. ESOP cost and NPA interest disallowances were rejected on consistency and RBI-linked treatment. Form 67 filing was held directory, so delayed claim of foreign tax credit could not defeat substantive entitlement. en-us Wed, 20 May 2026 00:00:00 +0530 Sat, 23 May 2026 08:27:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792137 Rule 8D disallowance under section 14A was not justified where the assessee had made a scientific suo motu computation and the Assessing Officer recorded no proper dissatisfaction. Interest on capital work in progress was also disallowed only where borrowed funds were used; if own funds exceeded the investment, no interest disallowance arose. Gains from sale of shares and units were treated as capital gains where the investments were strategic, long-term, and separately maintained from trading activity. ESOP cost and NPA interest disallowances were rejected on consistency and RBI-linked treatment. Form 67 filing was held directory, so delayed claim of foreign tax credit could not defeat substantive entitlement. Case-Laws Income Tax Wed, 20 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792137