AO can invoke Rule 8D only when he records satisfaction in regard to the correctness of the claim of the assessee

JK Investors (Bombay) Ltd, New  Vs. ACIT (ITAT Mumbai) –   ITA No.7858/Mum/2011 -Assessment year: 2008-09) – Date of Pronouncement: 13/03/2013

Assessing 0fficer can invoke Rule 8D only when he records satisfaction in regard to the correctness of the claim of the assessee, having regard to the accounts of the assessee. The condition precedent for the Assessing 0fficer entering upon a determination of the amount of the expenditure incurred in relation to exempt income is that the Assessing 0fficer must record that he is

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