Assessing Officer Can Apply Section 14A(2) Provisions Without Further Satisfaction If No Suo Motu Disallowance Made u/r 8D.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Addition u/s 14A r.w. Rule 8D(2)(iii) - In the present case, wherein the assessee does not offer any disallowance under Rule 8D(2)(ii) in respect of exempt income, then the provisions of section 14A(2) r.w. Rule 8D(2) can be invoked u/s.14A(3) of the Act by the AO and there is no necessity of recording further satisfaction by the AO - when the assessee itself fails to make disallowance suo motu u/s. 14A r.w. Rule 8D, then the AO is at liberty to invoke these provisions. - AT....