PCIT v. Godrej & Boyce Mfg. Co. Ltd. [2023] 149 taxmann.com 222 / 292 Taxman 497 (Bom)(HC)

S.14A : Disallowance of expenditure-Exempt income – Assessing Officer had not recorded any satisfaction that working of inadmissible expenditure under section 14A by assessee was incorrect, interest expenditure could not be disallowed. [R. 8D (2)(ii)]

Dismissing the appeal of the Revenue the Court held that where the assessee earned exempt income and submitted computation of inadmissible expenditure under section 14A, since Assessing Officer had not recorded any satisfaction that working of inadmissible expenditure under section 14A by assessee was incorrect, interest expenditure could not be disallowed. Order of Tribunal is affirmed. (AY. 2011-12)