AO Must Prove Need Before Rejecting Accounts or Applying Rule 8D for Exempt Income Disallowance u/s 14A.

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....Disallowance u/s 14A r.w. Rule 8D - until and unless this is proved or established by the revenue, the AO does not have any power to reject the accounts of the assessee and take the shelter of Rule 8D for computing the disallowance out of the exempt income - AT....