2015 (3) TMI 496

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....Appellant : Ms Urvashi Dhugga, Adv. For the Respondent : Mr Nitin Kaushal, Adv. ORDER Per: Rajive Bhalla: C.M.No.13733-CII of 2014 & C.M.No.14726-CII of 2014 1. Prayer in these applications are to condone delay of 07 days in filing the appeals. 2. Notice of the applications to counsel for the non-applicant-respondent. Counsel for the non-applicant-respondent states that he has no....

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.... Rules, 1962 operates prospectively had no jurisdiction to arbitrarily and abruptly reduce disallowance from Rs. 7,19,513/- to Rs. 1,00,000/- and Rs. 60,97,429/- to Rs. 5,00,000/- in ITA No.199 of 2014, and Rs. 7,55,849 to Rs. 1,23,754/-in ITA No.237 of 2014, without recording satisfaction much less by referring to any relevant facts. The impugned order, insofar as it has reduced the quantum of di....

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....D is prospective. A perusal of this Rule reveals that it does not, whether by words or intent, lend credence to the revenue's stand that Rule 8D is retrospective. The Tribunal, therefore, rightly placed reliance upon the judgment in Godrej & Boyce Manufacturing v. DCIT (supra), while holding that Rule 8D shall operate prospectively. 12. The matter, however, does not rest here. The Tribunal ....