2015 (5) TMI 810

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..... of the Appellant on the questions which have been termed as substantial questions of law. They are formulated in this Memo of Appeal by the Revenue at page 3. They read as under:             "(A) Whether on the facts and circumstances of the case and in law, the Hon'ble ITAT is right in setting aside and restoring back the issue to the f .....

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..... al questions of law. We are of the view that the Tribunal had only reiterated in paragraph 8 of the order under challenge delivered on 29th July 2011 the finding on the expenditure as per rule 8D r/w section 14A of the Income Tax Act 1961. In relation to that, the Tribunal held that Rule 8D is not applicable to the A.Y. Under consideration. Hence, applying the provisions of Rule 8D is not justifie .....

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