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2015 (4) TMI 1050 - AT - Income TaxDisallowance of interest u/s.14A read with Rule 8D - Held that:- No disallowance of interest is warranted. In case own funds are available with the assessee, it is presumed that investment has been made out of the own funds. It is also a matter of record that rule 8D Is not applicable for the relevant assessment year 2007-08 under consideration, however, reasonable disallowance is warranted as per verdict of Hon’ble High Court in case of Godrej & Boyce Mfg. Co. (2010 (8) TMI 77 - BOMBAY HIGH COURT ). In the interest of justice and fairplay, we restore this issue back to the file of AO for deciding afresh after considering assessee’s contention regarding interest free funds available to it more than the borrowed funds.- Decided in favour of assessee for statistical purposes. Addition as undisclosed professional receipts on the basis of Annual Information Return (AIR) - Held that:- Assessee has offered much more professional receipts than the professional receipts shown in the AIR. Accordingly, we do not find any merit in the addition so made by the AO which may be due to different accounting system being followed by payer of such fees. - Decided in favour of assessee.
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