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2016 (2) TMI 33 - AT - Income TaxDisallowance u/s 14A - Held that:- We find from bare reading of the assessment order that AO has clearly recorded his satisfaction that the assessee’s stand that no expenditure had been incurred in earning exempt income was incorrect and such arguments were completely misconceived. The observations have specifically been made in para 7.1 of the assessment order. He clearly observed that though there were no direct expenses shown by the assessee in his books of account exclusively for earning such exempt income, but it cannot be denied that the assessee had been utilizing its administrative as well as managerial machinery for earning the exempt income in a prudent manner. The claim of the assessee was that no expenditure was incurred for earning exempt income, but once the AO had recorded his satisfaction in terms of sub-section (2), then the disallowance can be made as per Rule 8D(2)(iii). We, accordingly, do not find any reason to interfere with the finding of ld. CIT(A) on this count - Decided against assessee
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