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

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