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2018 (4) TMI 738 - AT - Income TaxDisallowance u/s.14A - Held that:- The assessee was holding long term investments of ₹ 32.64 crores as at the beginning of the year and of ₹ 32.64 lacs as at the end of the year; that except for a miniscule investment of ₹ 15,000/- in unquoted Government securities, all the investments as at the beginning of the year were strategic investments in Appellant’s subsidiary companies; that all these investments came to be transferred to Arvind Limited with effect from 1st January, 2011 upon the Hon’ble Gujarat High Court passing an order dated 29/11/2011 approving demerger of the Appellant’s Investments Division which thereupon stood transferred to Arvind Limited. All the investments as at the end of the year viz. ₹ 32.64 lacs had been made by the revenue this year from its own funds in its subsidiary companies only; that thus, these investments too were strategic investments. Assessee was engaged in the business of trading of cloth and readymade garments; that its entire turnover of ₹ 94.85 crore came from this business; that on the other hand, as explained before, the Appellant’s investments were confined to strategic investments in its subsidiaries only. As assessee has not earned any tax free income and therefore, no expenses can be construed as incurred by the assessee we dismiss appeal of the department and in our opinion ld. CIT(A) has passed detailed and reasoned order. - Decided in favour of assessee
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