https://www.taxtmi.com/caselaws?id=466506 Assessing officer did not record the mandated satisfaction "having regard to the accounts" and ignored the assessee's scientific apportionment, so the suo moto disallowance by the assessee was adopted and the AO's disallowance under the provision for expenditure attributable to exempt income was deleted. For computation of book profit under the minimum alternate tax regime, one fiction cannot be superimposed on another; only expenses actually debited to the profit and loss account relating to exempt income are to be added back. Reliance noted on precedents requiring recorded satisfaction and on authorities limiting Rule based disallowance for MAT computation. en-us Thu, 27 Feb 2025 00:00:00 +0530 Tue, 10 Feb 2026 11:08:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466506 Assessing officer did not record the mandated satisfaction "having regard to the accounts" and ignored the assessee's scientific apportionment, so the suo moto disallowance by the assessee was adopted and the AO's disallowance under the provision for expenditure attributable to exempt income was deleted. For computation of book profit under the minimum alternate tax regime, one fiction cannot be superimposed on another; only expenses actually debited to the profit and loss account relating to exempt income are to be added back. Reliance noted on precedents requiring recorded satisfaction and on authorities limiting Rule based disallowance for MAT computation. Case-Laws Income Tax Thu, 27 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466506