PCIT v. Gujarat Fluorochemicals Ltd. (2021) 431 ITR 160 (Guj) (HC)

S. 14A : Disallowance of expenditure – Exempt income -Recording of satisfaction is mandatory –[ R.8D ]

Dismissing the appeal of the revenue the Court held that the Tribunal had found that the Assessing Officer had worked out disallowance on the basis of a formula. He failed to note that interest free funds available with the assessee were far more than the gross investment. The deletion of disallowance under section 14A was justified.( AY. 2005-06 to 2011-12)