Disallowance u/s 14A r.w.r. 8D in rectification proceedings u/s ...

Assessing Officer's satisfaction u/r 8D(2) is crucial for Section 14A disallowance; Section 154 rectification deemed invalid.

January 20, 2022

Case Laws Income Tax HC

Disallowance u/s 14A r.w.r. 8D in rectification proceedings u/s 154 - Mandation of recording satisfaction - Recording of satisfaction by the Assessing Officer under Rule 8D(2) of the Rules is mandatory. In the light of these provisions, the Assessing Officer invoking Section 154(2) to rectify the assessment order is wholly untenable for the reason that there is no mistake apparent on the face of the record to invoke the proceedings under Section 154 of the Act. - HC

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Disallowance u/s 14A r.w.r. 8D in rectification proceedings u/s ...

Assessing Officer's satisfaction u/r 8D(2) is crucial for Section 14A disallowance; Section 154 rectification deemed invalid.

January 20, 2022

Case Laws Income Tax HC

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