| 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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