AO must record non-satisfaction about suo-motu sec. 14a disallowance offered by assessee before applying Rule 8D

INCOME TAX : Disallowance of expenditure incurred to earn exempted income has to be a smaller part of such income and should have a reasonable proportion to exempted income earned by assessee in that year, which can be computed as per rule 8D only after recording satisfaction by Assessing Authority that apportionment of such disallowable expenditure under section 14A made by assessee or his claim that no expenditure was incurred is validly rejected by Assessing Authority by recording reasonable

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