Excessive disallowance u/s 14A was restricted as AO failed to record dissatisfaction

DCIT Vs Welspun Mercantile Limited (ITAT Mumbai) Conclusion: Excessive disallowance made under Section 14A was restricted as AO had failed to record any dissatisfaction with assessee’s claim regarding the expenditure incurred to earn tax-exempt income, which was a mandatory requirement before invoking Rule 8D for disallowance under Section 14A. Held: Assessee-company, had filed a nil return, showing income from business and short-term capital gains, both of which were adjusted against brought-forward losses for the assessment year 2014-15. During scrutiny, AO noted that assessee had earned a...