Dismissing the appeal of the Revenue the Court held that the when there is mixed funds the Rule 8D would be attracted is held to be not justified. Court also affirmed that disallowance cannot exceed exempt income. (AY. 2014-15)
PCIT v. Gujarat Flurochemicals Ltd. (2023) 459 ITR 242/ 295 Taxman 200 (Guj.)(HC)
S. 14A : Disallowance of expenditure-Exempt income-Mixed funds-Rule 8 would be attracted automatically is not correct-Disallowance cannot exceed exempt income.[R.8D]