ALP adjustment on AMP expenses barred by prior decision; amendment to section 14A read with Rule 8D not retrospective

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....HC dismissed the revenue's ALP adjustment in respect of advertising, marketing and promotional (AMP) expenses, holding that the addition was precluded by the HC's prior decision in the taxpayer's own case, which was followed by the tribunal; consequently no substantive or protective addition could be sustained on this score. Separately, HC held that the amendment to section 14A of the Act read with Rule 8D cannot be construed as retrospective where it operates to alter the pre-existing legal position despite being framed "for removal of doubts"; such language does not permit retroactive application to change settled law.....