Disallowance u/s. 14A r.w. Rule 8D - Mandation of recording...

Disallowance u/s. 14A r.w. Rule 8D - Mandation of recording satisfaction- We find that the AO had after exhaustively dealing with the contention advanced by the assessee that the disallowance of ₹ 4 lac (supra) offered in the return of income was quite reasonable qua the exempt dividend income, had on the basis of elaborate reasons as to why the said claim of the assessee company was not to accepted and the disallowance was required to be determined as per the mechanism provided in Rule 8D, therein, dislodged the suo motto disallowance that was offered by the assessee in its return of income. We, thus, not being persuaded to subscribe to the claim of the ld. AR that the Assessing Officer had failed to record his satisfaction that as to why the assessee's claim for disallowance u/s. 14A was not to be accepted, reject the same. - AT