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2018 (7) TMI 2135 - HC - Income TaxDisallowance of expenditure u/s 14A invoking Rule 8D - non recording of satisfaction - HELD THAT:- AO without recording required satisfaction on "having regard to the accounts of the Assessee, as placed before him, it is not possible to generate the requisite satisfaction with regard to the correctness of the claim of the Assessee", had invoked and applied Rule 8D as a mandatory provision applicable in all cases of exempt income. Action of the AO was contrary to law and, therefore, there is no merit in the present appeal. We have not affirmed and accepted the view expressed by the Commissioner of Income Tax (Appeals) that provisions of Section 14A and Rule 8D cannot be invoked in case the assesesee was an investment company, or the shares were procured for the purpose of the strategic investments, in view of the decision of Maxopp Investment Ltd. [2018 (3) TMI 805 - SUPREME COURT] - Appeal is dismissed in limine.
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