ACIT v. Karnataka Bank Ltd.(2018) 63 ITR 433 (Bang)(Trib.)

S. 14A : Disallowance of expenditure – Exempt income –Disallowances can be made only where the AO recorded his satisfaction as to how the claim of the Assessee that no expenditure was incurred to earn exempt income is incorrect. [R. 8D]

Dismissing the appeal of the revenue the Tribunal held hat; I  the absence of any finding by the Ld. AO as to how the claim of the Assessee that no expenditure was incurred for earning exempt income is incorrect, resort cannot be had to the provisions of sub-rule (2) of Rule 8D of the Rules. (AY. 2008-09 to 2011-12)