Dismissing the appeal of the revenue the Court held that for non -recording of satisfaction no disallowance can be made , hence adjustment to book profit does not arise . PCIT v. Gujarat State Fertilizer and Chemical Ltd [(2019) 416 ITR 13 (Guj) (HC) ( AY. 2012-13)
PCIT v. CIMS Hospital P. Ltd. (2020) 193 DTR 275 / (2021) 318 CTR 349 (Guj.)(HC)
S .14A : Disallowance of expenditure – Exempt income – Non recording of satisfaction – No disallowance can be made [ R.8D ]