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2016 (1) TMI 540 - AT - Income TaxDisallowance under section 14A r.w.r. 8D - Held that:- There has been no disallowance under section 14A which essentially proceeds on the accepted position that there has been no use of borrowed funds in this case. So far as fresh investments made in the present year are concerned, it is not in dispute that the sale proceeds of the mutual fund investments during the year has been used in making the investments. The disallowance even under rule 8D must therefore remain restricted to the amount worked out under rule 8D(2)(iii), 0.5% of the average value of investments appearing in the balance sheet as on 31.3.2007 and 31.3.2008, which works out to ₹ 26,951 as no part of the interest can be disallowed by invoking section 14A. We, therefore, restrict the disallowance to ₹ 26,951 and delete the remaining disallowance. Disallowance in respect of motor car expenses and depreciation - Held that:- This issue is now covered, in the case of assessee’s group Aflon Alplast Pvt Ltd for the same assessment year and in respect of similarly worded orders of the authorities below, in favour of the assessee Disallowance under section 40A(2)(b) - interest payment to the specified persons @ 24% pa, is excessive and unreasonable - Held that:- This issue is now covered, in the case of assessee’s group Aflon Alplast Pvt Ltd for the same assessment year and in respect of similarly worded orders of the authorities below, in favour of the assessee
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