In Brief
This case concerns whether Rule 8D of the Income Tax Rules, specifying how to compute expenditure relating to tax-exempt income, applies retroactively to assessments prior to 2007-08. The Supreme Court held that Rule 8D is prospective and applies only from Assessment Year 2007-08 onwards. The Court distinguished this from clarificatory amendments, finding Rule 8D introduced a novel methodology never before used by tax officers. The Finance Bill memorandum, departmental circular, and legislative language all indicated prospective operation. The Court rejected arguments that machinery provisions must follow substantive provisions retrospectively, holding instead that the specific legislative intent determines applicability. Accordingly, all revenue appeals seeking retroactive application were dismissed.
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