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2019 (11) TMI 928 - AT - Income TaxDisallowance u/s 14A read with Rule 8D - suo moto disallowance by assessee - absence of a speaking order by the Assessing Officer - HELD THAT:- Assessing Officer can invoke Rule 8D of I.T. Rules only after establishing with detailed reasons, through a speaking order, that the amount disallowed suo moto by the assessee is not satisfactory. The Assessing Officer having failed to do this, there is justification for applying Rule 8D is completely absent. In the absence of a speaking order by the Assessing Officer on why he invoked the jurisdiction under Rule 8D of Income Tax Rules, we are of the view that further disallowance made by the Assessing Officer lacked statutory credentials under section 14A(2) of Income Tax Act.
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