ITAT Replaces Rule 8D with Reasonable Estimate, Cuts ₹3.05 Cr Disallowance to ₹10 Lakh

Nitin Dwarkadas Nyati Vs ACIT (ITAT Pune)

Assessee, a builder & civil contractor, filed return declaring income of ₹36.73 crore. AO completed assessment u/s 143(3) r.w.s. 144B determining income at ₹40.41 crore after two additions —

(i) ₹3.05 crore u/s 14A r.w.r. 8D for expenditure relatable to exempt income, &

(ii) ₹50.79 lakh towards education cess, treating the same as not allowable in view of retrospective amendment by Finance Act 2022.

CIT(A) partly allowed the appeal — restricted

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