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2015 (10) TMI 306 - ITAT LUCKNOWDisallowance u/s 14A read with Rule 8D(ii) and 8D(iii) - Held that:- None of the judgments cited by the Learned A.R. of the assessee is rendering any help to the assessee. Moreover, the only explanation of the assessee regarding source of fund used for making investment was that the same is out of interest free advances received from customers but we have seen that the advances received from customers as on 31/03/2008 were not sufficient to cover the entire investment in shares of ₹ 694.84 lacs because the advance from customers as on 31/03/2008 was ₹ 122.04 lacs only. We have also seen that even if these advances were received by the assessee from the customers, the assessee must have incurred bank charges for providing bank guarantee to the customers. Hence, under these facts, the disallowance made by the Assessing Officer as per Rule 8D is very much in order and therefore, we do not find any reason to interfere in the order of CIT(A) on this issue. - Decided against assessee.
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