2020 (1) TMI 871

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..... industan Petroleum Corporation Ltd [ 2017 (8) TMI 197 - SUPREME COURT] is placed on record. It is a common ground that in view of this dicta of the Supreme Court, the substantial questions of law as framed will have to be answered against the Appellant Revenue. Disallowance u/s 14A - rule 8D applicability - HELD THAT:- As we proceed on the basis that principle laid down under Rule 8D of th .....

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..... Income Tax Appellate Tribunal. 3. The Appeal pertains to the Assessment Year 2003-2004. 4. The following questions have been raised by the Appellant Revenue as the substantial questions of law :- (A) Whether on the facts and in the circumstances of the case in law, the Income Tax Appellate Tribunal was justified in holding that bottling of the gas into gas cylinde .....

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..... ctly worked out as per the method of calculation prescribed in Rule 8D of the Income Tax Rules, 1962 ? (D) On the facts and circumstances of the case and in law, the Income Tax Appellate Tribunal erred in restricting the disallowance under Section 14A of the Income Tax Act read with 8D made by the Assessing Officer without appreciating that the method of working of disallowance is held .....

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