2014 (4) TMI 1301

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....AM For the Revenue : Shri Ravi Jain, CIT, DR For the Assessee: Shri Sanjay Bhaumik, Advocate ORDER PER BENCH: Appeal by revenue being ITA No. 1817/Kol/2008 is arising out of order of CIT(A)-VI, Kolkata in Appeal No. 193/CIT(A)-VI/07-08/C-6 dated 25.06.2008 and appeal by revenue being ITA Nos. 1819 and 1820/Kol/2008 are arising out of common order of CIT(A)-VI, Kolkata in Appeal Nos.....

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....matter to the learned Tribunal for decision in the light of the views expressed by us on the aforesaid questions of law." 3. Hon'ble High Court has set aside for consideration of disallowance by invoking the provisions of section 14A of the Act. However, Hon'ble High Court has held "the applicability of Rule 8D is prospective". At the outset, Ld. counsel for the assessee fairly stated that the ....