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2023 (8) TMI 1368 - HC - Income TaxDisallowance u/s 14A - Sufficiency of own interest free funds for investing - HELD THAT:- Tribunal restricted addition on the ground that assessee had sufficient interest free funds for investing in assets earning tax free income. Disallowance was made for administrative expenses. This issue, we have already examined in assessee’s Tax Appeals . [2018 (9) TMI 604 - GUJARAT HIGH COURT]. No separate discussion is necessary. Bad debt u/s 36(1)(viii) - Tribunal examined the claim at length and accepted the assessee’s stand inter alia observing that undisputedly the assessee is in the business of lease, financing and investment. The bad debts claim were in relation to higher purchase and lease transactions and were in respect of principal amount interest, penalty, bill discounting etc. The Tribunal therefore correctly observed that such bad debts arose out of the assessee’s ordinary course of business. No question of law arises. Addition of disallowance u/s.14A to the Book Profit u/s 115JB - Tribunal’s judgment in relation to deletion of disallowance under Section 14A of the Act, there would be no further question of considering its impact on the assessee’s computation of income for Section 115JB.
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