Dismissing the appeal of the revenue the Court held that Rule 8D of the Income tax Rules 1962 is prospective in operation and cannot be applied to any assessment year prior to assessment year 2008 -09. Followed Godrej and Boyce Manufacturing Co Ltd v. Dy. CIT ( 328 ITR 81 ( Bom) (HC) , CIT v. Essar Teleholdings Ltd ( 2018) 90 taxmann.com 2 (SC) (ITA No 2966 / 3085 /Mum/ 2014 dt 13-07- 2016 ) (ITA No .1996 of 2017 dt 23 –1 2020 )
PCIT v. Bank of India ( Bom) (HC) (UR)
S. 14A : Disallowance of expenditure – Exempt income – Rule 8D is not applicable to assessments prior to AY. 2008 -09 [R.8D]