Sub-sections (2) and (3) of sec. 14A and Rule 8D are constitutionally valid

Godrej & Boyce Mfg. Co. Ltd. Vs. DCIT (Bombay High Court) Brief: Bombay High Court rules on prospective operation of Rule 8D and upholds the constitutional validity of sub-sections (2) and (3) of section 14A and Rule 8D. Citation: Godrej & Boyce Mfg. Co. Ltd. Vs. DCIT (Bombay High Court), ITA No. 626/2010 and W.P. 758/2010 dated 12 August 2010 Facts: – The assessee filed its return of income for the Assessment Year (AY) 2002- 03 claiming exemption under section 10(33) (See Note-1 below) of the Income tax Act, 1961 (ITA) in respect of gross dividend earned on shares and units. In ...