COMMISSIONER OF INCOME TAX vs. M/S.KRUPAJAL TRUST

Accordingly, the review petitions are allowed and the order dated

Bench: DR. JUSTICE B.R.SARANGI,MR. JUSTICE GOURISHANKAR SATAPATHY

condoned. It is argued by learned ASG that the High Court has wrongly applied Rule 8D of the Income Tax Rules, 1962, inasmuch as, as per the judgment of this Court in Godrej & Boyce Manufacturing Co. Ltd. [(2017) 81 Taxmann.com 111 SC], the said rule has prospective application w.e.f. 01.04.2008 and the assessment year in question is 2002-03. Having

PRINCIPAL COMNR. OF INCOME TAX, SAMBALPUR RANGE vs. M/S. TATA SPONGE IRON LTD.

Bench: MR. JUSTICE ARINDAM SINHA,MR. JUSTICE SANJAY KUMAR MISHRA

delay in the clearance of the imported consignments, the appellants and its sister concern had been compelled to pay excess duty of over Rs 25 crores from August 2013 onwards. It is unfortunate and has to be accepted that the respondent authorities had compelled and forced the appellant to furnish the letter dated 6- 3-2017 thereby waiving