https://www.taxtmi.com/caselaws?id=354694 The SC held that Rule 8D of the Income Tax Rules, introduced to determine expenditure related to exempt income under Section 14A, operates prospectively and cannot be applied to assessment years prior to 2008-09. The court applied principles of statutory interpretation, including the maxim that new laws should govern future matters, not past ones. Despite sub-sections (2) and (3) of Section 14A being effective from April 1, 2007, Rule 8D was intended for prospective application only. The court examined the Finance Bill 2006's explanatory notes and departmental circular dated December 28, 2006, concluding that retrospective application was not intended. The decision favored taxpayers against the revenue department's position on applying Rule 8D to pending assessments for earlier years. en-us Wed, 31 Jan 2018 00:00:00 +0530 Tue, 28 Jul 2026 14:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=354694 The SC held that Rule 8D of the Income Tax Rules, introduced to determine expenditure related to exempt income under Section 14A, operates prospectively and cannot be applied to assessment years prior to 2008-09. The court applied principles of statutory interpretation, including the maxim that new laws should govern future matters, not past ones. Despite sub-sections (2) and (3) of Section 14A being effective from April 1, 2007, Rule 8D was intended for prospective application only. The court examined the Finance Bill 2006's explanatory notes and departmental circular dated December 28, 2006, concluding that retrospective application was not intended. The decision favored taxpayers against the revenue department's position on applying Rule 8D to pending assessments for earlier years. Case-Laws Income Tax Wed, 31 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=354694