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

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