https://www.taxtmi.com/highlights?id=34736 Application of Section 14A r.w.rule 8D - whereas in the earlier years AO did not make any disallowance - While it is true that the principle of res judicata would not apply to assessment proceedings under the Act, the need for consistency and certainty and existence of strong and compelling reasons for a departure from a settled position has to be spelt out which conspicuously is absent in the present case - SC en-us Tue, 09 May 2017 11:36:22 +0530 Tue, 09 May 2017 11:36:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=34736 Application of Section 14A r.w.rule 8D - whereas in the earlier years AO did not make any disallowance - While it is true that the principle of res judicata would not apply to assessment proceedings under the Act, the need for consistency and certainty and existence of strong and compelling reasons for a departure from a settled position has to be spelt out which conspicuously is absent in the present case - SC Highlights Income Tax Tue, 09 May 2017 11:36:22 +0530 https://www.taxtmi.com/highlights?id=34736