No specific format is provided U/s. 14A for recording satisfaction

The assessing officer while embarking upon calculating expenditure on the exempt income in terms of the provision of section 14A have only mentioned his satisfaction, in literally manner , however has not given the detailed reasons and has merely mentioned that he is not satisfied with the explanation offered by the assessee. In our view, it is the duty of the assessing officer to record the satisfaction for not satisfied with the explanation given by the assessee with respect to not incurring any expenditure by the assessee in respect of the extent income. In the present case, the assessing o...