Administrative expenses can not be disallowed under section 14A

So far as the dis allowance of administrative expenditure is concerned, we feel considering the fact that there is no precise formula for proportionate dis allowance, no dis allowance is called for, for proportionate administrative cost attributable to earning of tax free income until Rule 8D came into force. We, therefore, dispose of the appeals by setting aside the orders of the Tribunal and that of the first appellate authority on this issue and remand all the assessments back to the Assessing Officer for reworking dis allowance under Section 14A in the case

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