That the Assessing Officer has recorded vague, stereotyped reasons dehors the accounts of the assessee for making the disallowance under section 14A. There was no satisfaction of the Assessing Officer having regard to the accounts of the assessee. The disallowance made under section 14A in computing the total income under regular provisions was liable to be reversed. (AY. 2013-14).
Praxair India P. Ltd. v Dy. CIT (2023)101 ITR 640 (Bang)(Trib)
S. 14A : Disallowance of expenditure-Exempt income-Vague and stereotyped reasons for making disallowance-No satisfaction recorded-Disallowance to be reversed.[R. 8D]