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2017 (10) TMI 1652 - AT - Income TaxAddition u/s. 14A r.w.r. 8D - Mandation of recording satisfaction - HELD THAT:- We find that the issue involved in these appeals is squarely covered by the order of coordinate Bench in the case of assessee itself [2017 (6) TMI 495 - ITAT DELHI] held as AO did not record satisfaction after verification of the books of account about the correctness of the claim of disallowance made by the assessee before invoking provisions of Rule 8D as provided u/s 14A(2) of the Act. Therefore, respectfully following the decision of the Hon'ble Delhi High Court in CIT Vs. Taikisha Engineering Pvt. Ltd [2014 (12) TMI 482 - DELHI HIGH COURT] we reverse the finding of the ld CIT(A), and direct the AO to delete the disallowance. Thus following the above decision of coordinate Bench, the issue is decided in favour of the assessee and against the Revenue. The decisions relied by the ld. DR, being distinguishable on facts, render no help to the Revenue in the instant case. MAT - Addition of the disallowance to the book profit of assessee for the purpose of computation of MAT liability - As we find no justification to discard the findings reached by the ld. CIT(A) reached on the basis of interpretation of section 115JB. We also support the deletion of this addition laying our hands on the decision of Vireet Investment (P) Ltd [2017 (6) TMI 1124 - ITAT DELHI] Assessee appeal allowed.
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