Disallowance u/s 14A untenable for non-satisfying the formula contained in rule 8D

Ladderup Finance Ltd. Vs ACIT (ITAT Mumbai)

ITAT Mumbai held that AO had only recorded general satisfaction but not with reference to the accounts of the assessee and hence has not satisfied the formula contained in rule 8D in order to compute disallowance u/s 14A of the Act.

Facts-

The case of the assessee was selected for scrutiny and after serving statutory notices and providing opportunity of hearing, assessment order u/s 143(3) of t

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