Dismissing the appeal of the revenue the Court held that , since no such satisfaction was recorded by Assessing Officer, disallowance could not be made by applying rule 8D . (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 –No disallowance can be made without recording of satisfaction [ R.8D ]