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TMI Blog2017 (12) TMI 1870X X X X Extracts X X X X X X X X Extracts X X X X ..... - ITAT deleted addition - HELD THAT:- Whether the satisfaction of the Assessing Officer u/s 14A(2) that the disallowance offered by the Assessee, having regard to the Accounts, is not correct, is a sine-qua -non before invoking Rule 8D(2) of the Income Tax Rules. It is also an agreed position that it is so, in view of the decision of the Supreme Court in Godrej Boyce Manufacturing Co. Ltd[ 2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Income Tax Act, 1961 (the Act), challenges the order dated 27th May, 2014 passed by the Income Tax Appellate Tribunal (the Tribunal). The impugned order dated 27th May, 2014, is in respect of Assessment Year 2009 -10. 2 Revenue urges the following questions of law, for our consideration: (a) Whether on the facts and in the circumstance of the case and in law, the Tribunal was corre ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... me Tax Rules. It is also an agreed position that it is so, in view of the decision of the Supreme Court in Godrej Boyce Manufacturing Co. Ltd., v/s. DCIT 394 ITR 449. Thus, no fault can be found with the impugned order. (b) In the above view, Question No.1 does not give rise to any substantial question of law. Thus not entertained. 4 Reg. Question No.2: (a) Mr. Tejveer Singh, learned C ..... X X X X Extracts X X X X X X X X Extracts X X X X
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