Disallowance u/s 14A cannot be made without showing how the assessee’s calculation of disallowance is incorrect

Objective satisfaction of the AO as to the correctness of the assessee’s claim was not recorded in the instant case. However, even if Rule 8D cannot be applied, the AO is obliged to ascertain the expenditure which had been incurred to earn the tax-free income.

He must adopt a reasonable basis consistent with the relevant facts and circumstances of the case. The appellant’s dividend income during the year is Rs. 3,33,320/- and appellant estimated an expenditure of 2% of dividend income as related to e

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