https://www.taxtmi.com/caselaws?id=424404 Rule 8D cannot be applied retrospectively to compute disallowance under section 14A for assessment years before its prospective operation; the reduced ad hoc disallowance sustained by the CIT(A) was therefore upheld. On section 72A, approval of a demerger scheme by the High Court did not automatically entitle the assessee to carry forward and set off losses and unabsorbed depreciation of the demerged undertaking. As the undertaking was held for sale and business was not continued after demerger, the statutory object of revival was not satisfied, and the set-off claim was disallowed. en-us Mon, 27 Jun 2022 00:00:00 +0530 Wed, 29 Jun 2022 09:36:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=424404 Rule 8D cannot be applied retrospectively to compute disallowance under section 14A for assessment years before its prospective operation; the reduced ad hoc disallowance sustained by the CIT(A) was therefore upheld. On section 72A, approval of a demerger scheme by the High Court did not automatically entitle the assessee to carry forward and set off losses and unabsorbed depreciation of the demerged undertaking. As the undertaking was held for sale and business was not continued after demerger, the statutory object of revival was not satisfied, and the set-off claim was disallowed. Case-Laws Income Tax Mon, 27 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=424404