Section 14A disallowance based on invalid satisfaction not sustainable

HCL Comnet Ltd. Vs DCIT (ITAT Delhi) It is settled principle of law that generic dissatisfaction as to the correctness of the claim of the assessee without assigning any reason is not a valid satisfaction which is mandatory under section 14A(2) of the Act, as has been held by Hon’ble Supreme Court in case of Maxopp Investments Ltd. vs. CIT (2018) 402 ITR 640 (SC) and Hon’ble Delhi High Court in case of HT Media Ltd. vs. Pr.CIT 199 ITR 576 (Del.). So, when audited financials of the assessee company have otherwise been accepted by the AO, mechanical application of Rule 8D to reject the suo m...