2014 (9) TMI 1042

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.... under section 260A of the Income Tax Act, 1961 (the I.T. Act) is filed by the department challenging an order passed by the Income Tax Appellate Tribunal, Mumbai in two sets of cross appeals for assessment years 2006-07 and 2007-08. The Respondent-assessee bank had questioned the disallowance made by the assessing officer under section 14A of the I.T. Act read with Rule 8D of the Income Tax Rules....

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....he case and in law, the ITAT was correct in law by relying on the decision of the Bombay High Court in the case of Godrej & Boyce Mfg. Co. Ltd. V/s. DCIT (2010), 328 ITR 081 (Bom), wherein operation of Rule 8D was made prospective, disregarding the fact that method of working of disallowance provided in Rule 8D has been accepted as a reasonable method in the same judgment ? C. Whether on the fac....