The AO can only make additions under S.14A after considering the books of account of the assessee and recording his satisfaction thereupon not otherwise. (AY. 2005-06, 2007-08)
Dy. CIT v. Sahara Care Ltd. (2019) 74 ITR 117 (Delhi)(Trib. )
S. 14A : Disallowance of expenditure-Exempt income – Without recording satisfaction – No disallowances can be made. [R. 8D ]