If AO was satisfied as to assessee’s computation of disallowance U/s. 14A, invocation of rule 8D could not be allowed

Samvardhana Motherson International Ltd. Vs ACIT (Delhi High Court) The chronology of events leading up to the passing of the orders under section 143(3) of the Act, clearly shows that the assessing officer was ‘satisfied with the claim of the assessee’ while passing the original orders. Rule 8D is triggered only in a case where the assessing officer is not satisfied with the deduction made by the assessee. The reasons to believe assume and are predicated on the belief that the assessing officer should not have accepted the Petitioner’s deduction as explained and justified, albeit should...