TMI Blog2011 (8) TMI 148X X X X Extracts X X X X X X X X Extracts X X X X ..... ade out of the assessee's own funds and not out of the borrowed funds - Save and except contending that Section 14A was not on the statute book when the Income Tax Appellate Tribunal passed orders in the assessment years prior to the assessment year in question, Counsel for the Revenue could not point as to how interest on borrowed funds to the extent of Rs.2.79 crores was attributable to earning ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rores made in equity shares, mutual funds etc from assessment year 1994-95 onwards. 4. In the assessment year in question, the assessee had claimed deduction of interest amounting to Rs.8.70 crores on borrowed funds utilized for the business. Out of the said amount of interest, the assessing officer disallowed interest amounting to Rs.2.79 crores on the ground that the said amount was relatabl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... was not on the statute book when the Income Tax Appellate Tribunal passed orders in the assessment years prior to the assessment year in question, Counsel for the Revenue could not point as to how interest on borrowed funds to the extent of Rs.2.79 crores was attributable to earning dividend income which are exempt under Section 10(33) of the Act (as it then stood). Therefore, in the facts of the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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