https://www.taxtmi.com/caselaws?id=208569 HC held that s.14A(2)-(3) and Rule 8D operate prospectively, but AOs must still verify the correctness of an assessee's claim regarding expenditure related to exempt income for pre-Rule 8D periods. If satisfied, the AO must accept the claim and cannot compute a disallowance; if not satisfied after objective analysis and opportunity to be heard, the AO must reject the claim, record reasons, and determine disallowance using a reasonable, acceptable apportionment method. The court declined to decide whether Rule 8D is ultra vires s.14A. en-us Fri, 18 Nov 2011 00:00:00 +0530 Thu, 25 Sep 2025 17:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=208569 HC held that s.14A(2)-(3) and Rule 8D operate prospectively, but AOs must still verify the correctness of an assessee's claim regarding expenditure related to exempt income for pre-Rule 8D periods. If satisfied, the AO must accept the claim and cannot compute a disallowance; if not satisfied after objective analysis and opportunity to be heard, the AO must reject the claim, record reasons, and determine disallowance using a reasonable, acceptable apportionment method. The court declined to decide whether Rule 8D is ultra vires s.14A. Case-Laws Income Tax Fri, 18 Nov 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=208569