Section 14A Disallowance Deleted as AO Failed to Record Objective Satisfaction: ITAT Agra

ACIT Vs Bajaj Resources Pvt. Ltd. (ITAT Agra) In this case before the Income Tax Appellate Tribunal, the Revenue challenged the order of the Commissioner of Income-tax (Appeals)/National Faceless Appeal Centre dated 30.12.2025 for Assessment Year 2017-18. The dispute related to deletion of disallowance made under Section 14A of the Income Tax Act read with Rule 8D(2) of the Income Tax Rules. The assessee had filed its return of income on 27.11.2017 declaring income under normal provisions as well as under Section 115JB. During assessment proceedings, the Assessing Officer noticed that the asse...