Application of provision of section 14A r.w. Rule 8D without recording satisfaction cannot be upheld

Issue before Court: Whether CIT(A) was right in confirming the disallowance of Rs.39,40,500/- made by AO under Section 14A read with Rule 8D(2)(iii) of the Income Tax Rules without recording any satisfaction to the effect that the disallowance u/s 14A as computed by appellant was incorrect. Brief Facts: Assessee-company provides custodial & depository services to institutional investors, mutual funds and retail investors. Assessee filed its ROI at Rs. 85,72,598/-. Assesee showed book profit of 82,71,41,992/- under section 115JB of the Act. During the year under consideration assessee ear...