Kodagu District Co-Operative Central Bank Ltd. v. ACIT (2021) 431 ITR 356 (Karn)(HC)

S. 14A : Disallowance of expenditure – Exempt income -Recording of satisfaction is mandatory- Disallowance was deleted [ R.8D ]

Allowing the appeal of the assessee the Court held that  from a perusal of the order passed by the Assessing Officer it was evident that the Assessing Officer had not determined the amounts of the expenditure and had not recorded any reasons with regard to correctness of the claim made by the assessee in respect of expenditure, in relation to the income which did not form part of the total income. The disallowance under section 14A was not justified.( AY. 2009-10)