ACIT v. J. K. Fenner (India) Ltd. (2022) 220 TTJ 595 (Chennai)(Trib)

S. 14A : Disallowance of expenditure-Exempt income-Apportionment of interest-Not recording of satisfaction. [R. 8D(2)(iii)]

Held that the AO has not recorded any finding to establish nexus of borrowed funds with the investments made by the assessee, no disallowance of interest could be made  as satisfaction was not recorded.  (AY.  2008-09)