AdvertisementDeutsche Equities India Private Limited Vs ACIT (ITAT Mumbai) The cross appeals and cross objection before the ITAT Mumbai arose from the assessment for AY 2005-06 involving disallowances under Sections 14A, 40(a)(i), 40(a)(ia), transfer pricing adjustments, education cess, and transfer pricing tolerance margin. On Section 14A, the Tribunal held that Rule 8D was not applicable to AY 2005-06. It found that although the CIT(A) had accepted this position, he had adopted a computation resembling Rule 8D while enhancing the disallowance. Following judicial precedents, the Tribunal restricted the di...