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| The Tax Publishers2020 TaxPub(DT) 1867 (Mum-Trib) INCOME TAX ACT, 1961
Section 14A
Where no suo moto disallowance was offered by assessee despite earning exempt income in the form of dividend income and Long Term Capital Gains, then analysis of AO that most of income earned by assessee from dividend income and capital gains., was quite sufficient to establish that AO recorded requisite satisfaction before proceeding to compute disallowance under section 14A.
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Disallowance under section 14A - Recording of satisfaction by AO - No suo moto disallowance was offered by assessee despite earning exempt income in the form of dividend income and Long Term Capital Gains -
Issue was as regards disallowance under section 14A contending that AO did not record requisite satisfaction before proceeding to compute disallowance under section 14A. Held: No suo moto disallowance was offered by assessee despite earning exempt income in the form of dividend income and Long Term Capital Gains. AO specifically took note of fact that most of income earned by assessee was in form of dividend income and capital gains. The said analysis, was quite sufficient to establish that AO recorded requisite satisfaction before proceeding to compute disallowance under section 14A.
REFERRED :
FAVOUR : Against the assessee.
A.Y. :
INCOME TAX ACT, 1961
Section 14A
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