PCIT v. West Bengal Infrastructure Development Finance Corporation Ltd. (2022) 289 Taxman 312 (Cal.)(HC)

S. 14A : Disallowance of expenditure-Exempt income-suo motu disallowance-Failure to give cogent reason for dissatisfaction-Deletion of addition is justified. [R. 8D(2)(iii)]

Dismissing the appeal of the Revenue the Court held that the Assessing Officer had failed to give cogent reason of dissatisfaction regarding computation of disallowance under section 14A and had reached conclusion on mere ground that disallowance made suo motu by assessee was not convincing, addition made  was deleted.  (AY. 2013-14)