Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2014 (7) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2014 (7) TMI 907 - AT - Income TaxAdjustment of book profits – Held that:- CIT(A) has considered the sources of borrowed funds during the year - None of the loans have been utilized for the investment into shares of the companies - provisions of sub-clause (ii) of Rule 8D(2) are very clear on this wherein it has been provided that only interest expenditure is required to be considered which is not directly attributable to any particular income or receipt - there was no error in the findings of the CIT(A) in so far as interest expenditure of ₹ 16.22 crores is concerned – Decided against Revenue. Applicability of section 14A r.w Rule 8D - Non-consideration of balance interest and administrative expenses – Held that:- There is no mention of Special Purpose Vehicle in the assessment order nor the AO has given any findings on the net worth vis-à- vis investments of the assessee- the fact relating to the Special Purpose Vehicle was not before the AO, the matter is remitted back to the AO for fresh adjudication – Decided in favour of Assessee.
|