The assessee had made a suo motu disallowance under section 14A. The Assessing Officer invoked rule 8D without recording any dissatisfaction regarding the correctness of the assessee’s computation. The Tribunal held that recording of satisfaction under section 14A(2) is a mandatory pre-condition. In its absence, invocation of rule 8D was invalid, and the addition was directed to be deleted. (AY. 2017-18 & 2018-19).
SLK Software (P.) Ltd. v. Asst. CIT (2025) 127 ITR 395 (Bang.)(Trib.)
S.14A: Disallowance of expenditure-Exempt income-Recording of dissatisfaction mandatory before invoking rule 8D-Addition deleted. [R. 8D]
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