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2019 (4) TMI 258 - ITAT AHMEDABADAddition u/s 36(1)(iii) - addition of notional interest in WIP - own interest free funds available with the assessee - HELD THAT:- The assessee has reserves and surplus of more than ₹ 48 crores. It has internal accrual during the year which can take care of such investments. The assessee took us through net cash flow from operations available on page no.20 of the annual report which suggest that the assessee has net cash flow. Thus, considering interest free funds available with the assessee in the shape of share capital, reserves and surplus, as well as net revenue from operations, we are of the view that alleged investment in WIP could be assumed as carried from these surplus funds. No notional interest ought to be calculated for capitalization. See case of CIT Vs. Reliance Utilities & Power Ltd [2009 (1) TMI 4 - BOMBAY HIGH COURT] - Decided in favour of assessee.
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