COMMISSIONER OF INCOME TAX 5 MUMBAI vs M/S. ESSAR TELEHOLDINGS LTD. THROUGH ITS MANAGER

The Supreme Court addressed the applicability of Section 14A(2) and (3) of the Income Tax Act, 1961, determining that these provisions apply to all pending assessments and that Rule 8D is also retrospectively applicable. The Court held that the High Court's dismissal of the appeal by the Commissioner of Income Tax was incorrect, thereby allowing the appeal and setting aside the High Court's judgment. This ruling clarifies the retrospective nature of the provisions concerning income tax assessments.