2017 (2) TMI 34

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..... ce Mfg Co. Ltd vs. Deputy CIT reported in (2010 (8) TMI 77 - BOMBAY HIGH COURT ), the Division Bench of this Court in the case of Commissioner of Income Tax vs. Torrent Power Limited (2014 (6) TMI 185 - GUJARAT HIGH COURT ) has held that provision of Rule 8D shall be applicable prospectively and shall not be applicable with respect to earlier assessment years. In view of above concluded question, .....

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..... ed in ITA No. 1283/AHD/2012 for AY 2002-03, by which, the learned Tribunal has dismissed the said appeal preferred by the Revenue, the Revenue has preferred present Tax Appeal with the following proposed question of law. A. Whether the Appellate Tribunal has erred in law and on facts in deleting the disallowance of ₹ 2,25,20,176/made by the AO u/s. 14A of the Act ? B. Whether the .....

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..... ing to AY 2008-09 ? 3.0. We have heard Shri Manish Bhatt, learned counsel for the Revenue and Shri JP Shah, learned counsel for the assessee. Having heard the learned advocates for the respective parties and considering the proposed questions of law, the short question which is posed for the consideration of this Court is whether the Rule 8D of the Income Tax Rules shall be applicable retros .....

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