2019 (1) TMI 1639

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..... impugned judgment, while allowing the assessee's appeal came to the conclusion that the Assessing Officer had not recorded satisfaction with respect to the correctness of the claim of the assessee in respect of such expenditure. This is a requirement flowing from sub-section (2) of Section 14A of the Act. Only when sub-section (2) of Section 14A is made applicable, the question of having reso .....

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..... as offered by the assessee, without appreciating that when the assessee itself admitted that the disallowance had to be made with regard to expenditure for earning of income which was exempt, the disallowance is not to be worked out on adhoc basis by estimating the same, but as per method prescribed in the Rule 8D(2)? 2. The issue pertains to disallowance to be made under Section 14A of .....

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