Assessing Officer's Disallowance u/s 14A and Rule 8D Deemed Arbitrary and Unjustified for Dividend Income Expenditure.

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....Disallowance u/s. 14A read with Rule 8D - expenditure related to Dividend income - A bald assertion by AO that he is not accepting the assessee’s claim is arbitrary and so cannot be justified. The AO has not applied his mind while dealing with the issue and his action smacks of arbitrariness and therefore his action cannot be sustained.....