2021 (1) TMI 922 - HC - Income Tax

Disallowance u/s 14A - larger disallowance proposed by the Assessee himself in the computation of disallowance under Rule 8D - HELD THAT:- As relying on M/S. MARG LIMITED VERSUS COMMISSIONER OF INCOME TAX CHENNAI [2020 (10) TMI 102 - MADRAS HIGH COURT] we dispose of the present appeal by answering question of law in favour of the Assessee and against the Revenue and by holding that the disallowance under rule 8D of the IT Rules read with Section 14A of the Act can never exceed the exempted income earned by the Assessee during the particular assessment year and further, without recording the satisfaction by the Assessing Authority that the apportionment of such disallowable expenditure made by the Assessee with respect to the exempted income is not acceptable for reasons to be assigned the Assessing Authority, he cannot resort to the computation method under Rule 8D of the Income-tax Rules, 1962.