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2010 (10) TMI 126 - AT - Income TaxEffective date of section 14A(2), (3) - Sub-section (2) and (3) of Section 14A of the Act which has been inserted w.e.f. 1.4.2007 by Finance Act, 2006 - whether applicable from assessment year 2007-08 onward and not applicable in assessment year 2006-07 - Held that: - we find that the matter can not be set aside to the files of Assessing Officer to apply Rule 8 D as the said provision cannot be applicable for the current assessment year. - the assessee has urged that no expenditure has been identified to have been incurred to exempt income. Neither the Assessing Officer nor the Ld. Commissioner of Income Tax (Appeals) has rebutted these submission. Assessing Officer has gone into to make the adhoc estimate which is not sustainable in the light of [C.I.T. vs. Hero Cycles Ltd. (2009 -TMI - 35238 - PUNJAB AND HARYANA HIGH COURT)] decision - Decided in favor of assessee.
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