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2014 (7) TMI 503 - AT - Income TaxDisallowance u/s 14A r.w. Rule 8D of the Rules - Net worth of the company far exceeds its investments capable of yielding exempted income - Held that:- The AO has worked out the disallowance u/s 14A as per rule 8D after taking interest cost and administrative cost – assessee submitted that if any disallowance is called for, then it should be made on that basis only - the assessee’s networth and availability of funds is far more than investment which are capable of yielding exempt income and, therefore, no interest cost should be attributed for working out the disallowance - availability of interest free funds and investments which are capable of yielding exempt income, has not been examined properly either by the AO or by the CIT(A) – the decision in The Commissioner of Income Tax Versus Reliance Utilities & Power Ltd. [2009 (1) TMI 4 - HIGH COURT BOMBAY] – the AO is directed to re–examine the nexus of interest free funds and investment made – Decided partly in favour of Assessee.
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