https://www.taxtmi.com/caselaws?id=752906 The ITAT Delhi held that section 14A read with Rule 8D requires the AO to record objective satisfaction with specific linkage between expenditure and investment activity before rejecting the assessee's suo moto disallowance. The AO failed to provide cogent reasons for rejecting the assessee's claim and made identical observations as in previous assessment year where the tribunal had already deleted the disallowance. The CIT(A) correctly reduced the disallowance by considering only investments that actually yielded exempt income rather than total investments. The tribunal decided in favor of the assessee, emphasizing that re-computation under the provision requires proper satisfaction recording with regard to the assessee's accounts. en-us Fri, 17 May 2024 00:00:00 +0530 Mon, 20 May 2024 15:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752906 The ITAT Delhi held that section 14A read with Rule 8D requires the AO to record objective satisfaction with specific linkage between expenditure and investment activity before rejecting the assessee's suo moto disallowance. The AO failed to provide cogent reasons for rejecting the assessee's claim and made identical observations as in previous assessment year where the tribunal had already deleted the disallowance. The CIT(A) correctly reduced the disallowance by considering only investments that actually yielded exempt income rather than total investments. The tribunal decided in favor of the assessee, emphasizing that re-computation under the provision requires proper satisfaction recording with regard to the assessee's accounts. Case-Laws Income Tax Fri, 17 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752906