https://www.taxtmi.com/caselaws?id=800717 Section 14A(2) requires the Assessing Officer to examine an assessee's accounts and suo motu disallowance before recording dissatisfaction and applying Rule 8D. An additional Rule 8D disallowance cannot rest on an assumption that no disallowance was made where a voluntary disallowance exists; corresponding book-profit adjustment is consequentially unsupported. Expenditure attributable to qualifying royalty income under section 115BBF(2) must have a verified nexus with that income. Gross-receipts-based allocation of all expenses is inappropriate where royalty receipts include non-qualifying income or the expense base includes disallowed or manufacturing and trading expenses. Patent-wise evidence may require verification for fact-specific recomputation. en-us Thu, 17 Sep 2026 00:00:00 +0530 Sat, 10 Oct 2026 08:32:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800717 Section 14A(2) requires the Assessing Officer to examine an assessee's accounts and suo motu disallowance before recording dissatisfaction and applying Rule 8D. An additional Rule 8D disallowance cannot rest on an assumption that no disallowance was made where a voluntary disallowance exists; corresponding book-profit adjustment is consequentially unsupported. Expenditure attributable to qualifying royalty income under section 115BBF(2) must have a verified nexus with that income. Gross-receipts-based allocation of all expenses is inappropriate where royalty receipts include non-qualifying income or the expense base includes disallowed or manufacturing and trading expenses. Patent-wise evidence may require verification for fact-specific recomputation. Case-Laws Income Tax Thu, 17 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800717