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2015 (9) TMI 605 - ITAT DELHIDisallowance under section 14A read with Rule 8D - suo moto disalllowance - Held that:- It is seen that the appellant company itself has made the disallowance of expenditure u/s 14A r.w.r. 8D of ₹ 1,39,39,685/. The claim of disallowance made by the appellant company was examined by the AO during the course of assessment. The appellant produced the books of accounts and the evidences, which the ld. Assessing Officer had verified the ld. AO examined the books of accounts, evidences and records of the appellant and verified the voluntary disallowance by appellant u/s 14A of the Act. The AO has not pointed out any deficiency in the books of accounts nor in respect of claim of the appellant u/s 14A of the Act. In other words, the AO has not expressed satisfaction that the appellant’s claim u/s 14A is incorrect, a prerequisite for invoking the provisions of section 14A of the Act. In view of the aforesaid reasoning and findings we restrict the disallowance under sec.14A to be ₹ 1,39,39,685/-. - Decided in favour of assessee.
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