PCIT v. Security Printing and Mining Corporation of India Ltd. (2023) 459 ITR 261/295 Taxman 732 (Delhi)(HC)

S. 14A : Disallowance of expenditure-Exempt income-Not recording of satisfaction-Not examined the shared accounts-Order of Tribunal deleting the addition is affirmed.[R.8D, 260A]

Dismissing the appeal of the Revenue the Court held that  before recording  disbelief the  Assessing Officer did not examine even a shred of accounts of assessee.  Without looking into accounts of assessee, Assessing Officer held that assessee had infused funds by way of equity in joint venture company and also held that it was not believable that no expenditure had been incurred in relation to assets, income wherefrom did not form part of total income. High Court affirmed the order of the Tribbunal.(AY. 2014-15)