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2018 (9) TMI 1237 - ITAT BANGALOREDisallowance u/s 14A r.w. Rule 8D(2)(ii) - Held that:- AO has only made some general observations on the fund flow position; but could not point out any specific transactions OR identify any funds flow, specifically linked to diversion of interest bearing funds to share investment activity. The Assessing Officer has not controverted the assessee's stated position that it had sufficient own funds and reserves for investment in mutual funds and shares and that its interest bearing fund were specifically invested in those assets for which purpose it was taken for non-exempt business activity which is not within the purview of section 14A. No reason to interfere with or deviate from the findings of the learned CIT (Appeals) in deleting the disallowance u/s 14A r.w. Rule 8D(2)(ii). Consequently, grounds raised by Revenue are dismissed.
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