TMI BlogAO cannot mechanically apply the provisions of Rule 8D for the purpose of disallowance u/s 14A of the...AO cannot mechanically apply the provisions of Rule 8D for the purpose of disallowance u/s 14A of the Act. In our opinion, the same could be used only as a last resort only in the event of the AO not able to make a fair substitution of the disallowance figure as contemplated u/s 14A(2) of the Act. - AT ..... X X X X Extracts X X X X X X X X Extracts X X X X
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