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2021 (1) TMI 1046 - HC - Income TaxAddition u/s 14A read with Rule 8D - Appellant has not made any claim that it has not incurred any expenditure for earning the exempt income - as argued assessing officer has not arrived at the mandatory satisfaction as required under section 14A and hence no disallowance is possible - HELD THAT:- AO has not determined the amounts of the expenditure and has not recorded any reasons with regard to correctness of the claim made by the assessee in respect of such expenditure, in relation to the income which does not form part of the total income of the assessee. AO before embarking upon determination of the amount of expenditure incurred in the light of the exempted income, has to record a finding that he is not satisfied with the correctness of the claim of the assessee in respect of such expenditure. The aforesaid mandatory requirement has not been fulfilled by the Assessing Officer before disallowing the assessee under Section 14A - Decided in favour of assessee.
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