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2019 (1) TMI 1213 - BOMBAY HIGH COURTDisallowance u/s 14A as per Rule 8D - Held that:- Tribunal is on the basis of clear mandate of Section 14(2) of the Act which provides that the Assessing Officer will determine the amount of expenditure to be disallowed to earn exempt income as provided in Rule 8D of the Rules, as if he is not satisfied with suo motu disallowance made by the respondent. In fact this interpretation of Section 14A(2) of the Act by the Tribunal has now been taken in the case of Godrej & Boyce Manufacturing Co Ltd Vs. Dy. CIT & Anr [2017 (5) TMI 403 - SUPREME COURT OF INDIA] it is not possible to generate the requisite satisfaction with regard to the correctness of the claim of the assessee. It may only thereafter that the provisions of section 14A(2) and (3) read with rule 8D of the Rules or a best judgment determination, as earlier prevailing, would become applicable. No substantial question of law
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