14A applicable even for the period when Rule 8 was applicable

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Remi Sales And Engineering Ltd. Vs. Addl. CIT (ITAT Mumbai) - Even prior to Assessment Year 2008-09, when Rule 8D was not applicable, the Assessing Officer has to enforce the provisions of sub section (1) of section 14A. For that purpose, the Assessing Officer is duty bound to determine the expenditure which has been incurred in relation to income which does not form part of the total income under the Act. The Assessing Officer must adopt a reasonable basis or method consistent with al l the relevant facts and circumstances after furnishing a reasonable opportunity to the assessee to place all germane material on the record