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2015 (6) TMI 640 - AT - Income TaxDisallowance u/s 14A r.w.r. 8D(2)(iii) - Held that:- In view of the detailed working given by the assessee and following the ratio laid down in Godrej & Boyce Mfg. Co. Ltd. (2010 (8) TMI 77 - BOMBAY HIGH COURT) and Taikisha Engineering India Ltd. [2014 (12) TMI 482 - DELHI HIGH COURT] and Maxopp Investment Ltd. [2011 (11) TMI 267 - Delhi High Court] before applying the provisions of Rule 8D of the I.T. Rules, the AO was duty bound to record his dissatisfaction that the working of the disallowance made by the assessee under section 14A of the Act was incorrect. A perusal of the assessment order reflects that no such dissatisfaction was recorded by the AO and in view thereof the provisions of section 14A(2) of the Act had not been applied and accordingly we find no merit in the disallowance made by the AO under section 14A(2) of the Act read with Rule 8D without recording dissatisfaction that the working made by the assessee vis-à-vis the expenditure which is to be disallowed under section 14A of the Act was incorrect. - Decided in favour of assessee.
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