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2018 (4) TMI 1003 - HC - Income TaxDisallowance u/s. 14A restricted to the extent of 10% of dividend - Held that:- The issue of applicability of Rule 8D of the Income Tax Rules 1962 (Rules) as sought by the Revenue for the Assessment Year 2007-08 would have no application. This is so, as this Court in Godrej & Boyce Manufacturing Co. Ltd., v/s. DCIT [2010 (8) TMI 77 - BOMBAY HIGH COURT] has held that Rule 8D of the Rules would be applicable only from the AY 2008-09 onwards. Prior thereto, the disallowance, if any, would have to be on the reasonable basis. In the present facts, the CIT(A) and the Tribunal have restricted the disallowance to the extent of 10% of the dividend on a reasonable basis i.e. for Assessment Year 2007-08.
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