Satisfaction recorded by AO should not be based on conjectures & surmises

Ragavs Diagnostic & Research Centre Pvt. Ltd. Vs ACIT (ITAT Bangalore)

From the plain reading of section 69C, it is clear that when an assessee offers no explanation or the explanation offered is not satisfactory in the opinion of the AO, then the amount of such expenditure is to be taxed as income u/s. 69C of the Act. The satisfaction to be recorded by the AO should not be objective satisfaction exercised at his discretion, but a subjective satisfaction based on the facts of the case. It would then mean that justificati

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