Section 14A Disallowance: Rule 8D(iii) Not Automatically Applicable if Misaligned with Taxpayer's Investment and Business Expenses.

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....Disallowance u/s 14A - if at all any indirect expenses is to be attributable, then same has to be estimated having regard to the accounts and nature of expenditure incurred by the assessee. The blanket application of Rule 8D(iii) that is 0.5% of the average investment may not be acquired to do so because it is not commensurate with the nature of activity of investment carried out and the expenses debited by the assessee which is mostly for its business activities - AT....