2013 (10) TMI 224

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....the judgment and order of the Income Tax Appellate Tribunal (hereinafter referred to as "ITAT") dated 19.01.2012, raising following substantial question of law for our consideration:      "A Whether the Appellate Tribunal is right in law and on facts in deleting the disallowance u/s 14A of the act with respect to appointment of remuneration of the directors, travelling expen....

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.... had relied on the decision of the Bombay High Court rendered in the case of Godrej & Boyce Mfg. Co. Ltd. v. DCIT reported in [2010] 310 ITR 81 (Bom.), where it was held that Rule 8D is not retrospective. The Tribunal also relied upon the decision of the Kerala High Court rendered in the case of CIT v. Catholic Syrian Bank Ltd., Trissur, to hold that in absence of Rule 8D of the Income-tax Rules, ....