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The HC upheld the factual findings of the ITAT and CIT(A) that construction commenced after 1st October 1998, entitling the assessee to claim deduction under section 80IB(10), subject to other conditions. Regarding disallowance under section 14A read with Rule 8D, the HC concurred with the ITAT that Rule 8D applies prospectively from AY 2008-09 onwards. Consequently, the CIT(A)'s restriction of disallowance to 10% of exempt income was upheld as valid. The Court found no substantial question of law warranting interference, affirming the lower authorities' decisions on both issues.
The HC upheld the factual findings of the ITAT and CIT(A) that construction commenced after 1st October 1998, entitling the assessee to claim deduction under section 80IB(10), subject to other conditions. Regarding disallowance under section 14A read with Rule 8D, the HC concurred with the ITAT that Rule 8D applies prospectively from AY 2008-09 onwards. Consequently, the CIT(A)'s restriction of disallowance to 10% of exempt income was upheld as valid. The Court found no substantial question of law warranting interference, affirming the lower authorities' decisions on both issues.
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