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2009 (10) TMI 56

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..... ear and no part of investments were correlated with the borrowed funds. The CIT found that investment made in Zurich India Top 200 funds was advances from the loan and, therefore, only to this extent the interest could be disallowed under Section 14A of the Act - ITAT confirmed the order of CIT(A) – held that - no question of law, much less substantial question of law, arises for consideration – .....

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..... nk on which it had paid interest to the tune of Rs.40,51,126/-. On the other hand assessee had granted certain interest free advances. These advances were to the tune of Rs.39.65 lacs. The Assessing Officer was of the opinion that there was no business transactions with those who the assessee gave the loan advances and did not borrowed interest and, therefore, they had disallowed the proportionate .....

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..... ich was recorded was that the investment was made in the preceding year and no part of investments were correlated with the borrowed funds. The CIT found that investment made in Zurich India Top 200 funds was advances from the loan and, therefore, only to this extent the interest could be disallowed under Section 14A of the Act. Following is the relevant discussion in this behalf as noted by the T .....

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..... in respect of Flat No.801 and 802, International Trade Tower, Nehru Place. Assessee had claimed that she had half shares in both these flats and on all of these half shares depreciation was claimed. The Assessing Officer disallowed 50% of the depreciation claimed on the ground that two other firms namely M/s. PDK Stock and Securities and Ms/. Sidhi Vinayak Enterprises were also functioning from th .....

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..... was satisfied by the explanation and observed that the A.O. had no evidence to say that Shri Punit Kapoor and Smt. Sheila Kapoor were carrying on business from the said premises. He accordingly, deleted the addition aggrieved by which the revenue is in appeal before the tribunal." 2. We thus find that no question of law, much less substantial question of law, arises for consideration. 3. .....

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