Delite Infrastructure Private ... vs Assistant Commissioner Of Income-Tax, ... on 16 January, 2026
11. Regarding the judgment of hon'ble jurisdictional high court in the case of
DCIT vs. Jagson International Ltd (supra) relied upon by assessee, it is observed
that the Hon'ble Court has given its finding when the Assessing Officer has not made
any discussions about the amount suo motu disallowed by the assessee however, in
the instant case as observed above, Assessing Officer before invoking the provisions
of section 14A of the Act had recorded his satisfaction and thereafter proceeded to
make the disallowance as per Rule 8D of the Rules. Therefore, the ratio laid down
by the Hon'ble Jurisdictional High Court is not applicable to the facts of present
case.