Rule 8D not applies automatically on mere existence of mixed fund to disallowance u/s 14A

Pr. CIT Vs Gujarat State Petronet Limited (Gujarat High Court)

The language of Section 14A of the Act is plain and clear. Before invoking Rule 8D, the Assessing Officer is obliged to indicate that having regard to the accounts of the assessee, he is not satisfied with the correctness of the claim of the assessee in respect of such expenditure in relation to the income which does not form part of the total income under the Act. To put it in other words, the condition precedent of recording the requisite satisfaction which is

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