ITAT Deletes ₹28.78 Cr Section 14A Disallowance

The Income Tax Appellate Tribunal deleted a ₹28.78 crore interest disallowance under Section 14A, holding that when sufficient interest-free funds are available, a presumption arises against interest diversion. The ruling reinforces established jurisprudence on disallowance principles, offering relief to cooperative banks and taxpayers facing aggressive assessments. It strengthens predictability and fairness in income tax administration.