https://www.taxtmi.com/caselaws?id=201805 ITAT, MUMBAI allowed the assessee's claim for depreciation on goodwill and non-compete fees, applying the rule of consistency and treating these intangibles as part of a block of assets. It held Rule 8D of the Income Tax Rules 1962 applies only prospectively from A.Y. 2008-09, so it is not applicable to A.Y. 2005-06. Consequently, the disallowance of interest expenses under section 14A by the AO and confirmed by the CIT(A) was held unsustainable; the quantum of section 14A disallowance for pre-2008-09 years must be determined by a reasonable method. en-us Fri, 17 Sep 2010 00:00:00 +0530 Wed, 27 Aug 2025 11:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=201805 ITAT, MUMBAI allowed the assessee's claim for depreciation on goodwill and non-compete fees, applying the rule of consistency and treating these intangibles as part of a block of assets. It held Rule 8D of the Income Tax Rules 1962 applies only prospectively from A.Y. 2008-09, so it is not applicable to A.Y. 2005-06. Consequently, the disallowance of interest expenses under section 14A by the AO and confirmed by the CIT(A) was held unsustainable; the quantum of section 14A disallowance for pre-2008-09 years must be determined by a reasonable method. Case-Laws Income Tax Fri, 17 Sep 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=201805