Rule 8D Cannot Be Mechanical: Only Net Interest & Income-Yielding Investments Count, Says ITAT

Opelina Finance & Investment Ltd. Vs ITO (ITAT Delhi) Assessee had investments of ₹422 crore &  earned exempt dividend income. It voluntarily disallowed ₹3.40 crore u/s 14A. The AO, without recording proper satisfaction, mechanically applied Rule 8D &  made a total disallowance of ₹11.67 crore, adding an extra ₹8.27 crore. CIT(A) confirmed the disallowance in normal computation but deleted it from MAT. Before  Tribunal,  Assessee argued that the AO: did not record satisfaction as required under Section 14A(2); wrongly used gross interest instead of net interest; & ...