Disallowance u/s 14A untenable on mechanical application of rule 8D

Unilever India Exports Limited Vs ACIT (ITAT Mumbai)

ITAT Mumbai held that disallowance u/s 14A untenable as AO has mechanically applied rule 8D without having recorded his satisfaction or examining the nature of investments whether they have yielded any exempt income or not.

Facts- The assessee, Unilever India Exports Limited (UIEL) is a wholly owned subsidiary of Hindustan Unilever Limited (HUL). The assessee company is engaged in the manufacturing of branded FMCG products, namely Foods and Beverage

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