Suo-motto disallowance by Assessee cannot be disregarded by AO without recording his Satisfaction

Greatship (India) Ltd. Vs DCIT (ITAT Mumbai)

The assessee has further assailed the disallowance worked out by the A.O under Sec. 1 4A r.w Rule 8D, on the ground that there was no recording of an objective satisfaction by the A.O that the suo-motto disallowance offered by the assessee under Sec. 14A was not correct. Succinctly stated, the assessee company which during the year in question was in receipt of exempt dividend income of Rs. 1,05,08,214/- had on a pro-rata basis i.e percentage of exempt income to total income from investments suo-motto worked

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