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2023 (8) TMI 631 - ITAT SURATTPA on account of interest payment on FCCDs - HELD THAT:- As the assessee`s calculation of estimated mean coupon rate of 16.95% on the remaining six comparables, chosen from BSE/NSE appears to be closure. It was also observed by ld CIT(A) that the 15% coupon rate paid by the assessee on the FCCDs is close to the prevalent SBI prime lending rate of 14.75% as well. Considering these facts, ld CIT(A) held that the upward adjustment made by the TPO/assessing officer the total income of the assessee by reducing the interest rate paid @ 15% to 12.58% was held to be not justified and therefore ld CIT(A) deleted the same. We have gone through the above findings of ld CIT(A) and observed that conclusion reached by ld CIT(A) is correct. That being so, we decline to interfere with the order of Id. CIT(A) in deleting the aforesaid additions. His order on this addition is, therefore, upheld and the grounds of appeal of the Revenue are dismissed. Disallowance u/s 14 A - sufficiency of own funds - HELD THAT:- We note that during the appellate proceedings, the ld CIT(A) noted that assessee has sufficient tax-free funds available with it, which is verifiable from the copy of balance sheet attached with the financial statements filed. Investments that were brought forward at the beginning of the year (01.04.2014) were reduced to Nil at the end of the year (31.03.2015). Therefore, ld CIT(A) observed that since the assessee had sufficient interest free funds at its command as against the investments that resulted in earning of exempt income, hence ld CIT(A) deleted addition - No infirmity in the findings of ld CIT(A). The conclusions arrived at by the CIT(A) are, therefore, correct and admit no interference by us. We, approve and confirm the order of the CIT(A) and dismiss the ground raised by the Revenue.
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