Applicability of Disallowance U/s 14A Read With Rule 8D if objective satisfaction is not recorded

Brief Facts of the Case and Question of Law

Brief Facts:

These are cross appeals filed by the assessee and the revenue directed against two separate orders of Learned CIT (A) – II Lucknow both dated 07.01.2013 for A.Y. 2008 – 09 and 2009 – 10. All these appeals were heard together and are being disposed by this common order for the sake of convenience. In its appeals for both years, there was only one grievance of the assessee regarding disallowance u/s 14A sustained by the CIT (A) for Rs. 431,73,167 in A.Y. 2008 – 09 and Rs. 311,81,24,742 in A.Y. 2009 – 10.

Question of Law:

Whether the assessee’s contention is found acceptable relating to Section 14A applicable with Rule 8D.

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