Court Rules: Section 14A Prerequisite Must Be Met Before Applying Rule 8D for Mixed Fund Interest Expenses.

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....Addition u/s 14A r.w.r. 8D regarding interest expenses - mixed funds used for investments - the condition precedent of recording the requisite satisfaction which is a safeguard provided in Section 14A should not be overlooked before going to Rule 8D - Rule 8D would not be attracted automatically even if mixed funds are used - no disallowance....