Section 14A disallowance not sustainable if AO fails to records satisfaction about correctness of claim of assessee

Ambuja Housing & Urban Infrastructure Co. Ltd Vs DCIT (ITAT Kolkata)

It appears that while invoking Rule 8D of the I.T Rules, 1962 the AO has not pointed out/identified any specific infirmity in the disallowance so offered by the appellant/ assessee. A single sentence ‘explanation of the assessee was considered, but not acceptable’ has been made instead of giving specific reason for such non acceptance. It is evident from the records particularly the order passed by the Ld. AO that without recording satisfact

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