Suo motu disallowance offered couldn’t be rejected merely because such disallowance would be more under Rule 8D

INCOME TAX : An Assessing Officer cannot reject suomotu disallowance offered by assessee under section 14A on the ground that such a disallowance under Rule 8D of 1962 Rules will be more as that would be putting the cart before the horse. Quite to contrary, Assessing Officer can resort to Rule 8D of 1962 Rules only when as per provisions of section 14A(2),

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