TMI Blog2016 (5) TMI 1411X X X X Extracts X X X X X X X X Extracts X X X X ..... t expenditure to the tune of ₹ 84,20,803/- for A.Y. of 2004-05 and an amount of ₹ 7,70,012/- for the A.Y.2005-06. But in connection with the strategic investment in the subsidiary company the law is not quite clear that if any company made an investment in subsidiary company for commercial expediency or investment or stock in trade for any purpose of controlling interest in other compa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... der dated 28.03.2012 and 04.10.2010 passed by the Commissioner of Income Tax (Appeals)-14, Mumbai [hereinafter referred to as the CIT(A) ] relevant to the assessment year 2004-05 2005-06. These appeals are being taken up together for adjudication being the matter of controversy and the parties are same which can conveniently be adjudicated together. 2. The assessee company is engaged in the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... presentative of the assessee only raised the issue u/s.14A of the Income Tax Act, 1961( in short the Act ) wherein the learned CIT(A) confirmed the disallowance the interest expenditure to the tune of ₹ 8,42,08,035/- for A.Y.2004-05 and ₹ 9,70,012/- for A.Y.2005-06. The learned representative of the assessee has argued that the assessee expended the money for strategic investment with ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... idiary company for strategic investment i.e. for commercial expediency or investment or stock in trade is in question. Assessing Officer disallowed the interest expenditure to the tune of ₹ 84,20,803/- for A.Y. of 2004-05 and an amount of ₹ 7,70,012/- for the A.Y.2005-06. But in connection with the strategic investment in the subsidiary company the law is not quite clear that if any co ..... X X X X Extracts X X X X X X X X Extracts X X X X
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