https://www.taxtmi.com/caselaws?id=763632 ITAT Mumbai held that revision u/s 263 regarding disallowance u/s 14A read with Rule 8D was invalid. The assessee made suo motu disallowance which AO accepted after examining the explanation, being satisfied with its correctness based on accounts. PCIT could not substitute AO's satisfaction without proper enquiry. The assessee consistently followed same methodology in past years which was accepted in previous assessments. Since AO was satisfied with the explanation and accepted the suo motu disallowance consistent with past practice, the assessment order was not erroneous, making assumption of jurisdiction u/s 263 invalid. en-us Thu, 19 Dec 2024 00:00:00 +0530 Tue, 24 Dec 2024 08:28:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763632 ITAT Mumbai held that revision u/s 263 regarding disallowance u/s 14A read with Rule 8D was invalid. The assessee made suo motu disallowance which AO accepted after examining the explanation, being satisfied with its correctness based on accounts. PCIT could not substitute AO's satisfaction without proper enquiry. The assessee consistently followed same methodology in past years which was accepted in previous assessments. Since AO was satisfied with the explanation and accepted the suo motu disallowance consistent with past practice, the assessment order was not erroneous, making assumption of jurisdiction u/s 263 invalid. Case-Laws Income Tax Thu, 19 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763632