https://www.taxtmi.com/caselaws?id=466456 An assessing officer must record specific dissatisfaction with an assessee's claim before invoking the statutory disallowance mechanism for expenses relating to exempt income; absence of such recorded dissatisfaction invalidates the invocation of the disallowance rule. The officer rejected a taxpayer's suo moto 14A adjustment without referencing expenses or accounts and failed to deduct the taxpayer's offered suo moto disallowance from the rule based computation, resulting in a double addition. Because the officer acted on incorrect factual assumptions and without proper application of mind, the appellate authority disallowed the assessment additions and allowed the appeal for statistical purposes. en-us Mon, 29 Apr 2024 00:00:00 +0530 Mon, 09 Feb 2026 21:21:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466456 An assessing officer must record specific dissatisfaction with an assessee's claim before invoking the statutory disallowance mechanism for expenses relating to exempt income; absence of such recorded dissatisfaction invalidates the invocation of the disallowance rule. The officer rejected a taxpayer's suo moto 14A adjustment without referencing expenses or accounts and failed to deduct the taxpayer's offered suo moto disallowance from the rule based computation, resulting in a double addition. Because the officer acted on incorrect factual assumptions and without proper application of mind, the appellate authority disallowed the assessment additions and allowed the appeal for statistical purposes. Case-Laws Income Tax Mon, 29 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466456