Section 14A Disallowance Quashed Due to non Recording of Satisfaction: ITAT Mumbai

Piem Hotels Ltd. Vs DCIT (ITAT Mumbai) Income Tax Appellate Tribunal (ITAT), Mumbai Bench, has delivered a significant ruling in the case of Piem Hotels Limited, setting aside disallowances made under Section 14A of the Income-tax Act, 1961, for assessment years 2014-15 and 2016-17. The Tribunal’s decision, pronounced on May 8, 2024, hinged on the Assessing Officer’s (AO) failure to record proper satisfaction before invoking Rule 8D of the Income Tax Rules, a mandatory procedural requirement. Piem Hotels Limited, engaged in the business of running hotels, had filed appeals against ...