Assessing Officer Misapplies Rule 8D(2) for Section 14A Disallowance, Fails to Justify Rejection of Taxpayer's Voluntary Disallowance.

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....Disallowance u/s 14A read with rule 8D - Assessing Officer erred in invoking sub Rule (2) to Rule 8D, without elucidating and explaining why the voluntary disallowance made by the assessee was unreasonable and unsatisfactory. - AT....