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 ]

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)