ITAT Upholds 14A Satisfaction but Limits Rule 8D to Dividend Investments

PTC India Limited Vs DCIT (ITAT Delhi) 14A Satisfaction Upheld but 8D Must Apply Only to Dividend-Yielding Investments—Disallowance Recomputed; Unrealised Surcharge Not Taxable— Assessee earned ₹81.56 crore exempt dividend and suo-moto disallowed ₹49,51,789, based on a CA certificate allocating direct expenses of ₹15.41 lakh and 18% of indirect expenses of ₹1.87 crore. AO held the disallowance insufficient, recorded satisfaction citing lack of monthly investment details and high finance cost, and invoked Rule 8D, computing additional disallowance of ₹17,09,49,711. CIT(A) confirme...