Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
Disallowance u/s 14A - non recording of satisfaction - Suo moto disallowances were not commented upon by the Assessing Officer but were completely disregarded and no satisfaction for not accepting the suo moto disallowances was recorded by the AO.AR has also submitted that the disallowances may be restricted to the suo moto disallowance offered by the assessee company. Therefore, we sustain the disallowance u/s 14A, as offered by the assessee company accordingly. - AT
Disallowance u/s 14A - non recording of satisfaction - Suo moto disallowances were not commented upon by the Assessing Officer but were completely disregarded and no satisfaction for not accepting the suo moto disallowances was recorded by the AO.AR has also submitted that the disallowances may be restricted to the suo moto disallowance offered by the assessee company. Therefore, we sustain the disallowance u/s 14A, as offered by the assessee company accordingly. - AT
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