Pisces Portfolio Pvt. Ltd., New Delhi vs Assessee
42. Thus, the fact that we have held that sub-sections (2) & (3) of section 14A
and Rule 8D would operate prospectively (and, not retrospectively) does not
mean that the assessing officer is not to satisfy himself with the correctness of
the claim of the assessee with regard to such expenditure. If he is satisfied that
the assessee has correctly reflected the amount of such expenditure, he has to
do nothing further. On the other hand, if he is satisfied on an objective analysis
and for cogent reasons that the amount of such expenditure as claimed by the
assessee is not correct, he is required to determine the amount of such
expenditure on the basis of a reasonable and acceptable method of
apportionment. It would be appropriate to recall the words of the Supreme Court
in Walfort Share & Stock Brokers (P.) Ltd. (supra) to the following effect:-