Section 14A Disallowance Deleted for Mechanical Application & Lack of AO Satisfaction

Capricon Realty Private Limited Vs ITO (ITAT Mumbai) Mechanical 14A Disallowance Without Case-Specific Satisfaction—AO Ignored Assessee’s Detailed Explanation & Past ITAT Orders; Entire ₹56.14 Lakh Deleted – Assessee earned ₹57,09,646 dividend income and made a suo-moto disallowance of ₹95,584 u/s 14A (₹5,584 direct + ₹90,000 estimated indirect). AO, without rejecting books or pointing out any defect in the working, invoked Rule 8D and made an additional ₹56,14,060 disallowance. CIT(A) upheld it. During hearing, the Assessee demonstrated that: • Investments capable of e...