Dismissing the appeal of the revenue the Tribunal held that Assessing Officer had not made any observation and/or deliberation by recording satisfaction so as to correctness of claim of assessee in respect of expenditure in relation to income which did not form part of total income, invocation of rule 8D for disallowing expenses under section 14A was unsustainable. (AY. 2012-13)
DCIT v. DML Exim (P.) Ltd. (2020) 184 ITD 432 (Rajkot)(Trib.)
S. 14A : Disallowance of expenditure-Exempt income-Not recording of satisfaction-Disallowance is held to be not justified. [R. 8D]