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2017 (5) TMI 582 - HC - Income TaxDisallowance u/s 14A - Held that:- The investment in the earlier year was of ₹ 63,30,41,000/-. At the end of the current year, the amount came to ₹ 67,50,41,000/-. Thus, the increase of ₹ 4,20,00,000/- was on account of transfer of share application money to share allotment. The investments were made in the earlier year and no new investment had been made in the current year. Thus, as concluded that the investments made in the earlier year were made out of own funds of the assessee and no borrowed funds were used for such investments. It was further recorded that the interest paid during the year did not have any nexus to the investments and thus, no tax free income from these investments was earned. The findings above have been recorded by the Tribunal after appreciating the factual position on record and the relevant provisions of law, which have not been shown to be illegal or perverse by the learned counsel for the appellant. Thus, no substantial question of law arises. - Decided against revenue
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