Rule8d in rules shows with effect from 24/03/2008 sec 14A comes with effect from 1/04/2007 by finance act 2006 can assessing officer apply rule6d for A Y 07-08 ?
if so can he charge penalty u/s 271 (1) (c) since methodology was not available to assessee when he filed return for A Y 07-08 since rule came from 24/03/2008. return is filed in sept07for A Y 07-08
Dear Damle,
Sec 14 A was inserted with retrospective effect from 1961..
But Rule 8 D was inserted with 24/03/2008...
I don't think Rule 8D can be applied for assesssment year 2007-08 or earlier years..
But one thing I m sure that AO cannot impose penalty u/s 271(1)(c) in the present case since the said Rule was not there..
CCI
Pro
CAclubindia
