2017 (5) TMI 1788

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....nlal Lavidiya ORDER PER C.N. PRASAD (JM) This appeal is filed by the Assessee against the order of the Dispute Resolution Panel-II, Mumbai dated 27.9.2010 for the assessment year 2006-07. 2. The Assessee in this appeal raised several grounds on various issues. However, at the time of hearing, the Ld. Counsel submits that except ground no.1 regarding disallowance made u/s 14A of the Act....

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....4.2016 held that Rule 8D has no application prior to assessment year 2008-09 and therefore a reasonable disallowance should be made in view of the decision of the Hon'ble Bombay High Court in the case of Godrej & Boyce Manufacturing Co. Ltd. Vs. DCIT [328 ITR 81] and such reasonable disallowance was arrived at estimating the disallowance at 2% of the dividend income. The Ld. Counsel for the Assess....

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....e A.Ys. 2004-05 and 2005-06 and Rule 8D is not applicable in these two assessment years in view of the decision of the Hon'ble Bombay High Court in the case of Godrej & Boyce Mfg. Co. Ltd. v. Dy. CIT [2010] 328 ITR 81 (Bom). The Id. Counsel for the assessee stated that prior to the applicability of Rule 8D of the Rules, the disallowance should be restricted to a reasonable extent, i.e., 1% to ....