https://www.taxtmi.com/caselaws?id=794154 Rule 8D can be applied only after the Assessing Officer examines the accounts and records a reasoned dissatisfaction with the assessee's claim on expenditure relating to exempt income. The article explains that a mere rejection for want of evidence, without identifying missing material, examining fund-flow or cash-flow statements, or linking specific borrowed funds or expenditure to exempt dividend income, does not satisfy the statutory precondition under section 14A(2). The appellate order also did not cure this defect. Accordingly, the disallowance under section 14A read with Rule 8D, to the extent it exceeded the assessee's voluntary disallowance, was treated as unsustainable and deleted. en-us Thu, 25 Jun 2026 00:00:00 +0530 Wed, 01 Jul 2026 08:47:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794154 Rule 8D can be applied only after the Assessing Officer examines the accounts and records a reasoned dissatisfaction with the assessee's claim on expenditure relating to exempt income. The article explains that a mere rejection for want of evidence, without identifying missing material, examining fund-flow or cash-flow statements, or linking specific borrowed funds or expenditure to exempt dividend income, does not satisfy the statutory precondition under section 14A(2). The appellate order also did not cure this defect. Accordingly, the disallowance under section 14A read with Rule 8D, to the extent it exceeded the assessee's voluntary disallowance, was treated as unsustainable and deleted. Case-Laws Income Tax Thu, 25 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794154