JCIT (OSD) v. Rare Enterprises (2020) 84 ITR 164/(2021) 187 ITD 65 (Mum.)(Trib.)

S. 14A : Disallowance of expenditure-Exempt income-Satisfaction not recorded-Deletion of addition is held to be justified. [R. 8D]

Dismissing the appeal of the revenue the Tribunal  held that the Assessing Officer had not recorded his dissatisfaction with the disallowance worked out by the assessee to arrive at his conclusion of reasonable expenditure incurred to earn the exempt income and no books of account were examined. Hence the order of the Commissioner (Appeals) in restricting the quantum of expenditure in respect of earning exempt income to the amount claimed by the assessee was correct. (AY.2014-15)