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AO's Disallowance u/s 14A and Rule 8D Lacks Required Satisfaction, Highlighting Procedural Oversight.
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....Disallowance u/s 14A r.w.s 8D - AO did not in any manner reject explanation of the assessee but merely proceeded to make disallowance bu/s 14A - satisfaction of the AO about the correctness of the expenditure offered for disallowance by the assessee is a pre-condition for making disallowance....