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2022 (12) TMI 1467 - ITAT MUMBAIDisallowance u/s 14A r.w.r. 8D - Suo moto disallowance of the assessee - Mandation of recording satisfaction by AO - HELD THAT:- We find justification in the order of the ld. CIT(A) in upholding the A.O.’s action in invoking the provision of Rule 8D(2)(ii) by rejecting the assessee’s contention that suo moto disallowance by the assessee warrants no further disallowances. The assessee’s alternate claim is that the disallowance u/s. 14A r.w.r. 8D(2)(iii) should be restricted only to those investments on which exempt income was earned by the assessee during the impugned year, by placing reliance on the decision of Vireet Investments Pvt. Ltd. [2017 (6) TMI 1124 - ITAT DELHI] is acceptable. We uphold the order of the ld. CIT(A) in directing the A.O. to recompute the disallowance only to the investments which have yielded exempt income during the impugned year. Appeal filed by the Revenue is dismissed.
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