2014 (8) TMI 457

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....or the Respondent. ORDER P. C. 1. This appeal under Section 260A of the Income Tax Act, 1961 (the Act) by the revenue seeks to challenge the order dated 17.09.2010 of Income Tax Appellate Tribunal (the Tribunal) relating to Assessment Year 2005-06. 2. Being aggrieved by the order dated 17.09.2010 of the Tribunal the following questions have been formulated for consideration of this cou....

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....n of this court in the matter of Godrej & Boyce Mfg. Co. Ltd. reported in 328 ITR page 0081. In the above case, this court has held that Rule 8D of the Income Tax Rules, 1962 is applicable prospectively w.e.f. Assessment Year 2008-09, this appeal relates to Assessment Year 2005-06. Consequently, the Tribunal correctly held that Rule 8D of the Income Tax Rules, 1962 is inapplicable for the Assessme....