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2019 (4) TMI 978

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....Nitesh Joshi i/b Mr. Atul Jasani for Respondent. ORDER P. C. :­ 1. The Revenue is in Appeal against the Judgment of the Income Tax Appellate Tribunal raising the following questions for consideration. "(i) Whether on the facts and circumstances of thet case and in law, the Hon'ble ITAT was justified in restricting the disallowance under Rule 8D(2)(iii) to Rs. 2 Lakhs in each ....

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...., by the impugned Judgment, retained only a portion thereof.  The Revenue contends that once the disallowance is made in terms of Rule 8D, the Tribunal cannot provide for an ad­hoc formula.  We, however, notice that the amount involved is not substantial and the discussion contained in the Judgment of the Tribunal would essentially point to the fact whether such disallowance at all w....