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2019 (2) TMI 1412 - AT - Income TaxDisallowance u/s 14A r.w.r. 8D - sourcing of investment from borrowed funds or own funds - investment is taken as stock-in-trade of shares - ex-parte order - HELD THAT:- CIT(A) had rightly appreciated the facts of the present case to the effect that the assessee had made investment in exempt income earning avenues and earned dividend income during the year, but not made any disallowance by invoking rule 8D. From the records of balance sheet, the assessee’s own funds as on 31.03.12 were only ₹ 1.47 crores against the investment of ₹ 48.07 crores. The short term borrowings stands at ₹ 44.43 crores and thus after appreciating the documents, CIT(A) rightly appreciated that the investment was not sourced by the assessee from own funds, but was sourced from borrowed funds. Moreover, no new facts have been brought on record before us in order to controvert or rebut the findings so recorded by CIT (A). Therefore, the findings of the revenue authorities were un-rebutted and thus there are no reasons for us to interfere into or deviate from the findings recorded by the CIT (A). - Decided against assessee.
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