Dismissing the appeal of the revenue the Court held that the Asseee has made suo motu disallowance, however the AO applied the Rule 8D(2) of the Act. Tribunal held that the AO has not recorded the satisfaction for not accepting the disallowance hence, delted the addition. Order of Tribunal is affirmed by High Court. (ITA No. 237 of 2017, dt. 02.04.2019) (AY.2009-10)
PCIT v. Bajaj Finance Ltd( 2019) 178 DTR 219/ 309 CTR 28(Bom.)(HC), www.itatonline.org
S. 14A : Disallowance of expenditure-Exempt income–Not recorded the satisfaction for not accepting the disallowance- Deletion of addition is held to be justified. [R. 8D]