AO’s Mechanical Satisfaction under Rule 8D Invalid – ITAT Deletes ₹3.65 Cr 14A Disallowance  

Indraprastha Gas Limited Vs JCIT (OSD) (ITAT Delhi) Assessee, a leading distributor of CNG & PNG, filed its return declaring income of ₹914.49 crore.  AO completed assessment u/s 143(3) determining total income at ₹927.94 crore after making two adjustments- disallowance of additional depreciation u/s 32(1)(iia) & disallowance u/s 14A read with Rule 8D amounting to ₹3.65 crore. CIT(A) deleted the disallowance of additional depreciation but upheld the disallowance u/s 14A. Before Tribunal,  Assessee contended that it had already made a suo motu disallowance of ₹25.84 lakh u/s 1...