Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2014 (9) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2014 (9) TMI 1125 - ITAT MUMBAIAddition u/s 14A r.w.r. 8D - sufficiency of own funds - Held that:- The undisputed fact is that the assessee is having own funds in the form of share capital and reserves and reserves and surplus amounting to ₹ 101.31 crores as against the investments of ₹ 69.08 crores. This clearly shows that the assessee is having sufficient own funds to make the investment. Further, we find that out of the total investments of ₹ 69.08 crores, ₹ 66.68 crores are invested in subsidiary/associate companies. Further, we find that the loan liability of ₹ 25.25 crores as on 31.3.2008 has come down to ₹ 15.61 crores as on 31.3.2009 i.e. year under consideration. This also proves that there are no fresh borrowings during the year under consideration. No reason for the allocation of interest expenditure towards earning of exempt income. However, allocation of administrative and other expenses cannot be ruled out. The disallowance as per Rule 8D (2)(iii) as computed by the Ld. CIT(A) comes to ₹ 2,10,756/-. In our considered opinion, this disallowance would meet the ends of justice. The total disallowance sustained is ₹ 2,10.756/-. - Decided partly in favour of assessee.
|