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2019 (1) TMI 41 - HC - Income TaxAddition u/s 14A or 37 - strategic investments made by the respondent company in its subsidiary companies - Held that:- We notice that the assessee had made investments in its subsidiary companies and associated companies which were specially constituted as special purpose vehicle to execute the projects awarded by the local authorities. AO was of the opinion that the interest on the funds borrowed for making such investments would not be an allowable expenditure. The Tribunal relied upon and referred to the judgment of CIT Vs. Spencer & Co. Ltd.[2014 (2) TMI 237 - MADRAS HIGH COURT] and held that the interest on the borrowed capital were investments in shares utilizing borrowed capital for strategic business purpose, was an allowable expenditure. Without so stating, the Tribunal was essentially applying the principles laid down by the Supreme Court in case of S.A. Builders Ltd. Vs. CIT [2006 (12) TMI 82 - SUPREME COURT]
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