Tribunal held that, AO has neither considered contention of the assessee nor recorded the satisfaction hence disallowance is not justified. (AY 2007-2008, 2010 – 2011)
Garuda Imaging & Diagnostics (P) Ltd. v. ACIT (2018) 191 TTJ 765 (Delhi)(Trib.)
S.14A : Disallowance of expenditure – Exempt income – AO has neither considered contention of the assessee nor recorded the satisfaction, hence disallowance is not justified.[ R.8D ]