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Assessing Officer's Rejection of Assessee's Disallowance u/s 14A Implies Dissatisfaction Without Needing Explicit Documentation.

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....Disallowance u/s 14A - when he rejected the disallowance computed by the assessee, that in itself is dissatisfaction with the claim of the assessee of disallowance. It is not necessary that such dissatisfaction has to be recorded in explicit words, when the it is evident from the implied action of the Assessing Officer. - AT....