Tractor Engineers Ltd. v. Addl. CIT

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The Tax Publishers2013 TaxPub(DT) 0480 (Mum-Trib) : (2013) 049 (II) ITCL 0495 INCOME TAX ACT, 1961 --Disallowance under section 14A--Expenditure against exempt income--*Held:* In view of Bombay High Court decision in Godrej & Boyce Mfg. Co. Ltd. v. DCIT () 328 ITR 81 (Bom) : 2010 TaxPub(DT) 2182 (Bom-HC), rule 8D of the Income Tax Rules, 1962 is applicable only prospectively, i.e., from assessment year 2008-09. However, a reasonable disallowance for expenses incurred in earning dividend income is nevertheless to be computed by assessing officer. [Para 4] SUBSCRIBE FOR FULL CONTENT

The Tax Publishers2013 TaxPub(DT) 0480 (Mum-Trib) : (2013) 049 (II) ITCL 0495

INCOME TAX ACT, 1961

--Disallowance under section 14A--Expenditure against exempt income--Held: In view of Bombay High Court decision in Godrej & Boyce Mfg. Co. Ltd. v. DCIT () 328 ITR 81 (Bom) : 2010 TaxPub(DT) 2182 (Bom-HC), rule 8D of the Income Tax Rules, 1962 is applicable only prospectively, i.e., from assessment year 2008-09. However, a reasonable disallowance for expenses incurred in earning dividend income is nevertheless to be computed by assessing officer. [Para 4]