Dismissing the appeal of the revenue the Court held that the Tribunal had rightly concluded that the Assessing Officer had not recorded the satisfaction with regard to the claim of the assessee for disallowance under section 14A read with rule 8D(2). Section 14A was not applicable. (AY. 2009 -2010)
CIT v. Brigade Enterprises Ltd. (No. 2) (2020) 429 ITR 615 / (2021) 318 CTR 325 / 197 DTR 319 / 278 Taxman 81(Karn.)(HC)
S. 14A : Disallowance of expenditure-Exempt income-Failure by Assessing Officer to record dissatisfaction-No disallowance could be made. [R. 8D]