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2019 (4) TMI 190 - AT - Income TaxAddition u/s 14A read with rule 8D - assessee is having investments and earned dividend income which is exempt from tax - assessee has not shown any expenditure incurred - recording of satisfaction of AO - HELD THAT:- Assessee reiterated that there is no satisfaction by the A.O. that the assessee has not incurred any expenditure to earn the exempt income. In this regard, he placed reliance on several Tribunal decision in this regard. As regards the tribunal’s decision referred by the assessee, we find that they were rendered on the facts of the case, with a finding that there was no whisper by the A.O. regarding his satisfaction that the assessee has incurred expenditure to earn exempt income. In the present case, we find that it is not a whisper but a categorical finding and satisfaction of the A.O. that expenditure has been incurred to earn the exempt income. In our considered opinion, the CIT(A)’s finding to this effect is devoid of any infirmity. Except for calling the categorical satisfaction of the A.O., absence of satisfaction, the ld. Counsel of the assessee has not made out any case to negate the disallowance u/s. 14A. Hence, in the background of the aforesaid discussion, we do not find any infirmity in the order of the authorities below. Hence, we uphold the same. - Decided against assessee.
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