AO cannot apply Rule 8D without recording any satisfaction as to how assessee’s calculation of s. 14A disallowance was incorrect

DCIT Vs. Jindal Photo Limited (ITAT Delhi)– As per section 14A(2) of the Act, if the AO, having regard to the accounts of the assessee, is not satisfied with the correctness of the claim of the assessee in respect of expenditure incurred in relation to income which does not form part of the assessee ’s total income under the Act, the AO shall determine the amount incurred in relation to such income, in accordance with such method as may be prescribed, i.e., under Rule 8D of the I.T. Rules. However, in t

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