Tribunal held that the AO did not specify any cause of dissatisfaction with assessee’s working of suo moto disallowance and applied rule 8D mechanically. Accordingly the deletion of disallowance is held to be justified. (AY. 2010-11)
DCIT v. Pidilite Industries Ltd. (2019) 177 ITD 472 (Mum.) (Trib.)
S. 14A : Disallowance of expenditure-Exempt income–Suo–moto disallowance–Not recording of dissatisfaction- No disallowance can be made.[R. 8D]