Assessee’s computation of expense for exempt income not found inadequate so recourse to rule 8D invalid

PCIT-7 Vs UK Paints India Pvt. Ltd. (Delhi High Court)

Delhi High Court held that recourse to Rule 8D of Income Tax Rules for computing disallowance u/s. 14A not allowable since assessee’s computation of expense attributable to earning exempt income not found inadequate.

Facts- Revenue has preferred the present appeal mainly contesting the quantum of disallowance under section 14A of the Income Tax Act. Notably, assessee suo moto computed disallowance under section 14A to Rs. 7,50,000/-, whereas, AO computed disallowance under section 14A by applying rule

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