Sec. 14A of Income Tax Act, 1961— Business Disallowance — AO is not on the basis of the objective criteria and after giving the assessee a reasonable opportunity, satisfied with the correctness of the claim of the assessee, he shall have to reject the claim and state the reasons for doing so and having done so, the AO will have to determine the amount of expenditure incurred in relation to income which does not form part of the total income under the Act, therefore, AO was directed to disallow only 2% of expenses incurred towards exempted income. - ASPINWALL AND COMPANY LIMITED V/s ASSTT. CIT - [2020] 183 ITD 621 (ITAT-COCHIN)