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TMI Blog2018 (4) TMI 1003X X X X Extracts X X X X X X X X Extracts X X X X ..... t in Godrej & Boyce Manufacturing Co. Ltd., v/s. DCIT [2010 (8) TMI 77 - BOMBAY HIGH COURT] has held that Rule 8D of the Rules would be applicable only from the AY 2008-09 onwards. Prior thereto, the disallowance, if any, would have to be on the reasonable basis. In the present facts, the CIT(A) and the Tribunal have restricted the disallowance to the extent of 10% of the dividend on a reasonable ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the Appeal Memo, by substituting the new name M/s. Sprit Infrapower Multiventures Pvt. Ltd., in the place of M/s. Churu Trading Co. Pvt. Ltd., as the Appellant. (ii) Further, he seeks to substitute the Appeal Number before the Tribunal as indicated in the title of the Appeal Memo from Appeal No. 4778/M/2012 to Appeal No.5126/M/2012. 3. Mr. Bhansali, learned Counsel has no objection to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o the extent of 10% of dividend? 7. Mr. Mohanty, learned Counsel for the Revenue very fairly concedes that the issue of applicability of Rule 8D of the Income Tax Rules 1962 (Rules) as sought by the Revenue for the Assessment Year 2007-08 would have no application. This is so, as this Court in Godrej Boyce Manufacturing Co. Ltd., v/s. DCIT 328 ITR has held that Rule 8D of the Rules wo ..... X X X X Extracts X X X X X X X X Extracts X X X X
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