Taxpayer's Arguments Rejected; Disallowance Upheld u/r 8D, Section 14A of Income Tax Act.

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....Disallowance u/s. 14A - recording of satisfaction - AO before invoking Rule 8D has issued SCN to the assessee. The AO after considering the reply of assessee negated the same giving reasons and thereafter made disallowance under Rule 8D. AO has recorded his satisfaction as envisaged u/s. 14A(3)- disallowance upheld....