2018 (7) TMI 2135

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.... For the Respondent : None ORDER This appeal under Section 260A of the Income Tax Act, 1961 ("Act‟ for short) preferred by the Revenue impugns order of the ITAT dated 31.8.2017 passed in ITA No.5569/Del/2005 in the case of M/s Hindustan Clean Energy Ltd., and relates to assessment year 2011- 2012. Question raised pertains to disallowance of expenditure of Rs. 99,09,017/- made by th....

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.... Whether such determination is to be made on application of the formula prescribed under Rule 8D or in the best judgment of the Assessing Officer, what the law postulates is the requirement of a satisfaction in the Assessing Officer that having regard to the accounts of the Assessee, as placed before him, it is not possible to generate the requisite satisfaction with regard to the correctness of t....