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2021 (3) TMI 663 - AT - Income TaxDisallowance u/s 14A r.w.r. 8D - assessee filed detailed submissions and contested that no objective satisfaction were recorded by the Assessing Officer for invoking Rule 8D of the Rules - assessee also contested that the investment was made in the sister concern for holding/controlling stake and not for earning any income from out of the investment - HELD THAT:- We find that the issue of the strategic investment in group concern has already been adjudicated by the Hon’ble Supreme Court in the case of Maxopp Investment Ltd. & Ors. Vs. CIT, [2018 (3) TMI 805 - SUPREME COURT]. The Hon’ble High Court held that “such strategic investment is also subject to the disallowance under Section 14A of the Act”. We find that the objection of the assessee on the absence of dissatisfaction for invoking Rule 8D of the Rules, have already been dealt with by the learned CIT(A). The learned CIT(A) has referred the decision of India Bulls Financial Services Ltd. [2016 (11) TMI 1369 - DELHI HIGH COURT] wherein it has held that “if the Assessing Officer has carried out elaborated analysis out of the facts and the issue but did not expressly record his dissatisfaction, would not per se justify that he has not recorded cogent reason for his dissatisfaction”. In our opinion, the learned CIT(A) has dealt with all the objections of the assessee, therefore, we do not find any infirmity in the same. Accordingly, we uphold the findings of the learned CIT(A) on the issue in dispute. The grounds of appeal of the assessee are accordingly dismissed.
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