Invocation of rule 8D without recording objective satisfaction by the Assessing Officer is not proper

Issue before tribunal:

• Whether provision of section 14A read with rule 8D can be invoked without recording any satisfaction by AO that the claim made by the assessee in respect of the expenditure incurred in relation to income which does not form part of the total income is incorrect.
• Whether interest income on funds deposited in bank supplied by Govt. for the disbursement to the employees of UPTRON India Limited under the Voluntary Retirement Scheme (VRS) can be taxed in hands of the assessee.

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