Tribunal held that the assessee had filed details of expenses which were suo moto disallowed by it which showed that suo moto disallowance included expenses which were coming under purview of rule 8D(2)(iii) . Accordingly without verifying the facts disallowance of expenses by applying rule 8D(2)(iii) is held to be not justified .( AY.2013-14)
Olive Bar & Kitchen (P.) Ltd. v. DCIT (2019) 175 ITD 72 (Mum.)(Trib.)
S. 14A : Disallowance of expenditure-Exempt income-suo moto disallowance–Further disallowances made by the AO is held to be not justified. [R. 8D(2)(iii)]