Commissioner of Income Tax-III, vs. M/s Sree Rayalaseema Green Energy Limited,

272 (Del.). Further to invoke Rule 8D, the Assessing Officer has to first record a finding that he was not satisfied with the correctness of the claim for expenditure made by the assessee in relation to income, which did not form part of the total income under the Act. No such satisfaction has been recorded by the Assessing Officer