Court Vacates Disallowance u/s 14A, Rule 8D Due to Authorities' Failure to Record Satisfaction for Jurisdiction.

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....Disallowance u/s 14A r.w.r. 8D - failure to record satisfaction - as there is a clear lapse on the part of the lower authorities in validly assuming jurisdiction for dislodging the assessee’s claim that no disallowance u/s.14A of the Act was called for in its hands, therefore, the disallowance worked out by the Assessing Officer u/s 14A r.w Rule 8D(2)(iii), which thereafter, had been sustained by the CIT(Appeals) is liable to be vacated. - AT....