2011 (9) TMI 1168

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....S h. Krishna, C.I.T.(D.R.) ORDER PER SHAMIM YAHYA: AM This appeal by the Assessee is directed against the order of the Ld. Commissioner of Income Tax (Appeals) dated 24.11.2010 pertaining to assessment year 2006-07. 2. The issue raised is that Ld. Commissioner of Income Tax (Appeals) erred in upholding the disallowance of ` 11,42,32,000/- and ` 3,66,72,225/- made by the Assessing Officer u/....

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..... 2006-07 and Rule 8D is clearly not applicable. 6.1 It was further held that even prior to A.Y. 2008-09, when Rule 8D was not applicable, the Assessing Officer has to enforce the provisions of sub-section (1) of Section 14A. For that purpose, the Assessing Officer is duty bound to determine the expenditure which has been incurred in relation to income which does not form part of the total income....