Assessing Officer Must Justify Dissatisfaction Before Applying Rule 8D for Disallowance u/s 14A of Income Tax.

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....Disallowance u/s 14A r.w.r. 8D(2)(iii) - it is settled legal position that before proceeding to invoke provisions of Rule 8D of the Rules for computing disallowance u/s 14A AO must express his dissatisfaction regarding the computation of disallowance made by the Assessee. - AT....