AO Must Justify Inadequate Disallowance u/s 14A Before Applying Rule 8D Based on Taxpayer's Accounts.

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....Disallowance u/s 14A - it was incumbent for Ld. AO to record a satisfaction as to why the disallowance offered by the assessee was not sufficient and this said satisfaction was to be arrived at having regard to assessee’s books of accounts. The recording of the said satisfaction was sine qua non before proceeding to apply Rule 8D. - AT....