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2014 (6) TMI 1006 - AT - Income TaxDisallowance u/s 14A - reasonable disallowance u/s 14A - Held that:- As relying on case of Godrej Boyce Mfg. Co. Ltd vs. DCIT [2010 (8) TMI 77 - BOMBAY HIGH COURT] it is held that the provisions of Rule 8D shall apply w.e.f AY 2008-2009, prior to which the AO has to enforce the provisions of section 14A(1) by adopting the “reasonable basis on method consistent with all the relevant facts and circumstances after furnishing a reasonable opportunity to the assessee to place all germane material on the record.” In this backdrop, find that the disallowance u/s 14A in the appellant’s case being relatable to AY 2007-08 has to be worked out on a reasonable basis. Section 145A applicability - addition on account of service tax - Held that:- As decided in M/s. Knight Frank (India) Pvt Ltd vs. Addl CIT [2013 (7) TMI 1033 - ITAT MUMBAI] the fact is that the assessee is a service provider company and patently, provisions of section 145A cannot be made applicable, because the provision was specifically introduced for the purposes of manufacture segment of business because section 145A(a)(ii) submitted before the CIT (A) mentions “.by the assessee being goods to be place of location & conditions as on the date of valuation are required to be included”.
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