Held that interest-free funds of the assessee being in excess of the investments made by it which are generating tax-free income, and the AO having not recorded his dissatisfaction under S. 14A(2) before invoking R. 8D, the disallowance made by the AO under s. 14A is not sustainable in law. (AY. 2018-19, 2020-21)
Urmin Products (P) Ltd. v. Dy. CIT (2024) 231 TTJ 100 (UO) (Ahd)(Trib)
S.14A : Disallowance of expenditure-Exempt income-Interest free funds-Not recorded dissatisfaction-Addition is deleted. [R.8D]
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