COURT: | |
CORAM: | |
SECTION(S): | |
GENRE: | |
CATCH WORDS: | |
COUNSEL: | |
DATE: | (Date of pronouncement) |
DATE: | October 10, 2008 (Date of publication) |
AY: | |
FILE: | |
CITATION: | |
(1) For purposes of s. 14A, only the expenditure which is proved to have a nexus with the exempt income can be disallowed and not on an ad-hoc basis.
(2) Sub-secs (2) and (3) of s. 14A inserted with effect from the AY 2007-2008 {and Rule 8D} (which sanction proportionate disallowance) are prospective and do not apply to earlier assessment years.
Note: The judgement of the Bombay ITAT in Citicorp Finance 108 ITD 457 was not followed.
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