Tax Disallowance u/s 14A Capped, Not Final; Interest Allowance Pending; Assessee's Claims Invalidated by Rulings.

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....Disallowance u/s 14A is limited to Rs.2,77,80,538/- and cannot be treated as an enhancement of assessment. Neither assessee nor AO mentioned a specific figure linked to the allowance of interest paid. When the allowance of interest has not reached finality, the quantum of disallowance u/s 14A cannot be considered final. The first appellate authority omitted to consider the disallowable amount u/s 14A, which the Commissioner rectified u/s 154, permissibly. The Supreme Court judgments in South Indian Bank Limited and Maxopp Investment Ltd. clarified that Section 14A aims to prevent double benefit by disallowing expenditure related to exempt income. The Supreme Court in T.S.Balaram and MEPCO Industries Limited held that a mistake apparent on r.........