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2018 (2) TMI 1938 - AT - Income TaxDisallowance u/s 14A r.w.r. 8D(2)(iii) - HELD THAT:- The availability of own funds of the assessee to the tune of ₹ 28.85 crores and the fact that the closing value of investment in the balance sheet as on the last date of the previous year was ₹ 22.3 crores clearly demonstrates that the assessee had sufficient own funds which were more than the value of investments. Apart from the above the source of investments on each of the investments made by the assessee during the previous year has been explained by the assessee in a chart filed before CIT(A). The factual accuracy of this chart has not been disputed by the revenue. In such circumstances we find no merits in this appeal by the revenue challenging the deletion of addition in terms of Rule 8D(2)(ii) of the rules,. In so far as the disallowance of other expenses under Rule 8D(2)(iii) of the rules is concerned we are of the view that direction of CIT(A) to include only investments which yielded dividend income while computing average value of investments before applying the formula of Rule 8D(2)(iii) of the Rules is in accordance with the decision of the tribunal in the case of REI Agro Ltd [2013 (9) TMI 156 - ITAT KOLKATA] - Decided against revenue.
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