https://www.taxtmi.com/caselaws?id=751226 The Bombay HC upheld the CIT(A) and ITAT's decision allowing the assessee's appeal regarding addition under Section 14A read with Rule 8D. The AO failed to record proper dissatisfaction with the assessee's claim regarding expenditure related to exempt income. While the AO stated the assessee's explanation was unacceptable, he provided no cogent reasons for this conclusion. The court emphasized that under Section 14A(2) and Rule 8D, the AO must record dissatisfaction with correctness of expenditure claims and provide reasons before determining expenditure amounts. The HC referenced JSW Energy Limited and Sesa Goa Limited precedents supporting this requirement for reasoned dissatisfaction. en-us Wed, 03 Apr 2024 00:00:00 +0530 Thu, 07 May 2026 17:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751226 The Bombay HC upheld the CIT(A) and ITAT's decision allowing the assessee's appeal regarding addition under Section 14A read with Rule 8D. The AO failed to record proper dissatisfaction with the assessee's claim regarding expenditure related to exempt income. While the AO stated the assessee's explanation was unacceptable, he provided no cogent reasons for this conclusion. The court emphasized that under Section 14A(2) and Rule 8D, the AO must record dissatisfaction with correctness of expenditure claims and provide reasons before determining expenditure amounts. The HC referenced JSW Energy Limited and Sesa Goa Limited precedents supporting this requirement for reasoned dissatisfaction. Case-Laws Income Tax Wed, 03 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751226