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2014 (8) TMI 1007 - ITAT MUMBAIDisallowance u/s 14A - Held that:- The balance sheet of the assessee shows that it has interest free funds amounting to ₹ 14,88,38,332/-, the investment is at ₹ 9,71,56,751/-, which clearly shows that the assessee was having sufficient interest free funds to make the investment. A further perusal of the balance sheet shows that the assessee was having loan funds as on 31/03/2007 at ₹ 33,29,48,063/- whereas the loan funds as on 31/03/2008 is at ₹ 1,36,00,000/-, which shows that there is a substantial fall in the loan funds which means that there are no fresh borrowings during the year under consideration. See Reliance Utilities and Power Ltd [2009 (1) TMI 4 - HIGH COURT BOMBAY] Thus in our considered view, there is no basis for deeming that the assessee had used the borrowed funds for investments in tax free securities. From the analysis of the balance sheet, the assessee had enough interest free funds at its disposal for making its investment. We therefore set-aside the findings of the CIT(A) and direct the AO to delete the addition made u/s 14A of the Act. - Decided in favour of assessee
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