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2016 (8) TMI 1371 - AT - Income TaxDisallowance u/s 14A r.w.r.8D - Held that:- It is noted that the investment worth ₹ 3. 37 crores have been made by the assessee in the earlier years and not in the year under consideration. Even if one were to consider the availability of interest free funds during the year, it is noted that partner’s capital account is worth ₹ 115.70 crores. The secured loans availed by the assessee in form of Packing Credit Limit (PCL) and Post Shipment Export Finance (PSEF) from various bank are exclusively for the purpose of purchase of raw material, payment of labour charges and other direct expenses and which thus have a end-use restriction and monitoring by the banks towards the manufacturing and export activity of the appellant. Thus giving the availability of interest free funds over and above the secured loans and also the fact that the secured loans had a specific end-use restriction, the investments have been made from its internal accruals in the earlier years and given that no expenditure has been incurred, no disallowance u/s 14A is warranted.
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