2013 (2) TMI 664

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...., is against the impugned order dated 29th January 2011, passed by the learned Commissioner (Appeals)-XII, Mumbai, for the quantum of assessment passed under section 143(3) of the Income Tax Act, 1961 (for short "the Act"), for the assessment year 2007-08, on the following grounds:- "On the facts and in the circumstances of the case and in law, the learned CIT(A) erred in directing the Assessing ....

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....lying the provisions of Rule 8D, calculated the disallowance of Rs. 76,15,743, under section 14A. The Commissioner (Appeals) held that the provisions of Rule 8D, cannot be applied for the assessment year 2007-08, therefore, the working of Rule 8D, as applied by the Assessing Officer, will not be applicable. He, accordingly, held that a reasonable amount of deduction should be made for making the d....