Assessing Officers Must Justify Higher Disallowance u/s 14A; Rule 8D Not Automatic Without Satisfaction.

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....Disallowance u/s 14A - Mandation of recording satisfaction - suo motu disallowance made by assessee - where suo motu disallowance has been made, the Assessing Officer is required to form ‘satisfaction’ in terms of Section 14A of the Act for higher disallowance which has not been made and thus the formula provided for quantification of disallowance under Rule 8D would not automatically apply.Disallowance cannot exceed the actual expenditure incurred in relation to the earning of the exempt income - AT....