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2022 (6) TMI 1398 - AT - Income TaxDisallowance u/s 14A r.w.r. 8D - Sufficiency of own funds - HELD THAT:- On perusal of the balance sheet of the assessee as on 31.03.2016 we observed that the assessee has share capital and reserves and surplus as on 1.04.2015 at 145173.31 lakhs and whereas the investments during the year under consideration stood at 1957.39 lakhs. In the case of South Indian Bank Ltd. Vs. CIT [2021 (9) TMI 566 - SUPREME COURT] it has been held that if investments in securities is made out of common funds and the assessee has availed non-interest bearing funds larger than the investments made in tax-free securities then in such cases disallowance u/s 14A cannot be made. On observing the balance sheet, we find that the assessee has sufficient own funds much more than the investments. Thus we delete the disallowance made under Rule 8D(2)(ii) made - Decided against revenue. Disallowance relating to prior period expenses - CIT-A deleted the addition - HELD THAT:- For the assessment year 2009-10 [2014 (11) TMI 1174 - ITAT DELHI] accepted the claim of the assessee for netting off of prior period income against prior period expenses. Decided against revenue.
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