2013 (10) TMI 224

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..... Appellate Tribunal (hereinafter referred to as "ITAT") dated 19.01.2012, raising following substantial question of law for our consideration:      "A Whether the Appellate Tribunal is right in law and on facts in deleting the disallowance u/s 14A of the act with respect to appointment of remuneration of the directors, travelling expenses etc." 2. The issue pertains to disall .....

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..... Court rendered in the case of Godrej & Boyce Mfg. Co. Ltd. v. DCIT reported in [2010] 310 ITR 81 (Bom.), where it was held that Rule 8D is not retrospective. The Tribunal also relied upon the decision of the Kerala High Court rendered in the case of CIT v. Catholic Syrian Bank Ltd., Trissur, to hold that in absence of Rule 8D of the Income-tax Rules, no disallowances can be made under Section 14A .....

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