Disallowance u/s. 14A without recording proper satisfaction untenable: ITAT Cochin

Condis India Helathcare Pvt. Ltd. Vs ACIT (ITAT Cochin) ITAT Cochin held that disallowance under section 14A read with rule 8D of the Income Tax Rules in a mechanical manner without recording proper satisfaction is unsustainable in law. Accordingly, addition set aside. Facts- AO during the course of assessment proceedings found that the assessee has shown dividend income of Rs. 2,88,51,340/- claiming the same as exempted from tax u/s 10(34) of the Act. However, the assessee has not made any disallowance under the provisions of section 14A r.w. rule 8D corresponding to such exempted income. Thu...