Rule 8D not applicable if AO not recorded dis-satisfaction with correctness of claim of assessee

Pr. CIT Vs. Reliance Capital Asset Management Ltd. (Bombay High Court)

The assessing officer did not specifically record that he is not satisfied with the correctness of the claim of the assessee in respect of the expenditure in relation to the income which does not form part of the total income under the Act. However, he felt obliged and going by the presence of rule 8D that once section 14A is attracted, the dis allowance is to be made as per rule 8D only which has been prescribed by the Legislature. The ass

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