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2018 (6) TMI 1237 - KARNATAKA HIGH COURTDisallowance 14A read with Rule 8D - non recording of satisfaction - Held that:- The disallowance under Section 14A cannot be a wild guesswork bereft of ground realities. It has to have a reasonable and close nexus with the factually incurred expenses. It is not deemed disallowance under Section 14A of the Act but an enabling provision for assessing authority to compute the same on the given facts and figures in the regularly maintained Books of Accounts. The assessing authority also could not have called upon the Assessee himself to undertake the exercise of computing the disallowance under Section 8D of the Rules. Such abdication of duty in not permissible in law. See THE COMMISSIONER OF INCOME TAX, THE DEPUTY COMMISSIONER OF INCOME TAX VERSUS M/S MICROLABS LTD. [2016 (4) TMI 219 - KARNATAKA HIGH COURT] - decided against revenue
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