Tribunal held that since assessee has not furnished any evidence to prove its contention that the investment in tax free bond thereof are made in earlier years. As rule 8D have incorporated for the AY. 2008-09 onward sassessee squarely covered with the provision of S. 14A(3) which makes it mandatory to make disallowance as per the provision of section 14A (2) r.w. rule 8D of Income-tax Rules, 1962.
Dy.CIT v. Rasna Pvt Ltd. ( No 2) (2018) 66 ITR 689 (Ahd.)(Trib.)
S. 14A : Disallowance of expenditure – Exempt income -Disallowance has to be made where the assessee cannot furnish any evidence to prove that the investments were made in earlier years.[ R. 8D]