The Bombay High Court reiterated that Rule 8D would apply only from Assessment Year 2008-09, following the decision of the jurisdictional High Court in Godrej & Boyce Manufacturing Co. Ltd. (328 ITR 81 / 4 Taxman 203) (Bom). The High Court further noted that the issue had also come before the Hon’ble Supreme Court in CIT v. Essar Teleholdings Ltd. [2018] 90 taxmann.com 2 / 253 Taxman 321 / 401 ITR 445 (SC), which affirmed that Rule 8D is prospective in operation and cannot be applied to assessments prior to AY 2008-09. (AY. 2007-08)