https://www.taxtmi.com/caselaws?id=292055 The Tribunal found that the Assessing Officer (AO) failed to record satisfaction regarding the correctness of the assessee's disallowance under Section 14A of the Income Tax Act, 1961, before applying Rule 8D. This procedural oversight rendered the AO's enhanced disallowance unsustainable. Consequently, the Tribunal partly allowed the appeals for the assessment years 2008-09 to 2011-12, upholding the assessee's grounds related to the improper application of Rule 8D, while dismissing another ground as not pressed. The decision emphasized the necessity of recording objective satisfaction by the AO before invoking Rule 8D. en-us Tue, 28 Nov 2017 00:00:00 +0530 Wed, 13 Nov 2024 12:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=292055 The Tribunal found that the Assessing Officer (AO) failed to record satisfaction regarding the correctness of the assessee's disallowance under Section 14A of the Income Tax Act, 1961, before applying Rule 8D. This procedural oversight rendered the AO's enhanced disallowance unsustainable. Consequently, the Tribunal partly allowed the appeals for the assessment years 2008-09 to 2011-12, upholding the assessee's grounds related to the improper application of Rule 8D, while dismissing another ground as not pressed. The decision emphasized the necessity of recording objective satisfaction by the AO before invoking Rule 8D. Case-Laws Income Tax Tue, 28 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=292055