In the result, the appeal of the assessee is partly allowed
ii) of the Rules. Similarly, in the absence of any specific plea from assesse towards disallowance under Rule 8D (3), we hold it sustainable in view of express mandate of law. The matter is accordingly remanded back to the file of the Assessing Officer for re-computation of disallowance under Rule 8D r.w.s. 14A of the Act in terms