Invocation of rule 8D without recording of satisfaction contravenes section 14A(2)

Shri Ashok M. Wadhwa Vs ACIT (ITAT Mumbai) As AO failed to arrive at satisfaction as to non-correctness of assessee’s claim as regards no expenditure against exempt income, invocation of rule 8D was in contravention of section 14A(2) and, therefore, disallowance was deleted. Briefly stated, the facts pertaining to the issue under consideration are that the assessee had shown dividend income of Rs. 48,67,603 as his exempt income. However, no expenditure was attributed by the assessee in respect of the said exempt income. The assessing officer taking support of the judgment of the Hon’ble H...