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2016 (12) TMI 801 - AT - Income TaxDisallowance u/s 14A r.w.r. 8D - Held that:- The assessee admittedly borrowed funds for the purpose of business and paid interest. The interest paid by the assessee is not relatable to any particular income. Therefore, the second limb of Rule 8D(2) is squarely applicable. We have carefully gone through the order of the Assessing Officer. The Assessing Officer has found that there was no direct expenditure relating to income which does not form part of total income. Therefore, he computed the disallowance under the second limb of Rule 8D(2) and also computed the average amount / expenditure to the extent of ₹ 8,66,34,771/-. Therefore, this Tribunal is of the considered opinion that the CIT(Appeals) has rightly confirmed the order of the Assessing Officer. This Tribunal do not find any reason to interfere with the order of the lower authority and accordingly the same is confirmed.- Decided against assessee
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