TMI Blog2016 (12) TMI 1487X X X X Extracts X X X X X X X X Extracts X X X X ..... wherein it has been held that the transaction charges paid to the Stock Exchange are not subject to deduction of tax at source under Section 194J of the Act. Application of Rule 8D of the Income Tax Rules to disallow expenses on exempt income - Held that:- Tribunal followed the decision of this Court in Godrej & Boyce Manufacturing Co. Ltd., v/s. DCIT [2010 (8) TMI 77 - BOMBAY HIGH COURT ] wher ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Tribunal is correct in holding that the issue of deduction of TDS on transaction charges with the Stock Exchange was debatable prior to A. Y. 2006-07 and therefore the tax is not deductible at source for the impugned assessment year? (b) Whether on the facts and in the circumstance of the case and in law, the Tribunal is correct in holding that Section 194J is not applicable on the ground ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Godrej Boyce Manufacturing Co. Ltd., v/s. DCIT 328 ITR 81 wherein it has been held that Rule 8D of the Income Tax Rules can be invoked only from Assessment Year 2008-09 onwards. (b) The grievance of the Revenue as formulated herein above is that even for Assessment Year prior to A. Y. 2008-09, the Tribunal ought to have applied Rule 8D of the Income Tax Rules to disallow expenses on exempt i ..... X X X X Extracts X X X X X X X X Extracts X X X X
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