Disallowance Upheld Due to AO’s Satisfaction: ITAT Confirms Rule 8D Application

J.M. Financial & Investment Consultancy Services Pvt. Ltd. Vs DCIT (ITAT Mumbai)

ITAT Mumbai upheld the AO’s recorded dissatisfaction and confirmed Rule 8D-based disallowance, including interest allocation, after finding inconsistencies in the assessee’s 14A workings, insufficient evidence of own funds, and impermissibility of netting interest. The Tribunal, however, remanded the matter only for Vireet-compliant recomputation of average investments, partly allowing the appeal for statistical purposes.

Assessee, an NBFC earning substantial exe

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