https://www.taxtmi.com/caselaws?id=472593 The Finance Act, 2022 amendment to section 14A operates prospectively and does not govern assessment years 2017-18 and 2020-21. Rule 8D computation requires the Assessing Officer to record, after examining the accounts, dissatisfaction with the correctness of the taxpayer's own disallowance; general observations on investments, mixed funds, or administrative expenses do not meet that condition. A notional section 14A disallowance cannot be added to book profit under section 115JB merely through clause (f) of Explanation 1, which is confined to specified amounts debited to the profit and loss account. The additional disallowance and corresponding book-profit adjustment are unsustainable. en-us Tue, 31 Dec 2024 00:00:00 +0530 Fri, 16 Oct 2026 18:43:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472593 The Finance Act, 2022 amendment to section 14A operates prospectively and does not govern assessment years 2017-18 and 2020-21. Rule 8D computation requires the Assessing Officer to record, after examining the accounts, dissatisfaction with the correctness of the taxpayer's own disallowance; general observations on investments, mixed funds, or administrative expenses do not meet that condition. A notional section 14A disallowance cannot be added to book profit under section 115JB merely through clause (f) of Explanation 1, which is confined to specified amounts debited to the profit and loss account. The additional disallowance and corresponding book-profit adjustment are unsustainable. Case-Laws Income Tax Tue, 31 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472593