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Khandelwal Laboratories Pvt. Ltd. Versus CIT-6, Mumbai

2016 (8) TMI 898 - ITAT MUMBAI

Revision u/s. 263 - disallowance of STT u/s. 14A - Held that:- Profit on sale of F & O transaction is amounting to ₹ 22,62,70,605/- which is shown as a taxable income. Therefore the STT paid on the derivative transactions is allowable as an expenditure w.e.f. AY 09-10 as amended by the Finance Act, 2008. The STT paid on sale of shares of L & T, the company has made a loss on these shares at ₹ 14,37,81,950/- which was offset with the capital gains. Therefore if the same is to be consi .....

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ebited to P&L A/c. During this year the assessee has also received the interest on deposits from banks and others at ₹ 1,56,65,399/-. Net interest of ₹ 48,18,532/- is required to be considered for disallowance u/s. 14A. The same view was taken in ITAT Mumbai, in the case of Morgan Stanley India Securities Pvt Ltd Vis ACIT [2014 (1) TMI 1412 - ITAT MUMBAI]and ITAT Ahemdabad in the case ITO vs. Karnavati Petrochmem Pvt Ltd.[2014 (1) TMI 920 - ITAT AHMEDABAD ]. Thus the view taken by AO .....

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nce-sheet placed on record investment as on 31/3/09 is ₹ 15,91,91,128/-. However, the increase in investment is out of the fund received on sale of brand of ₹ 113 crores i.e. interest-free. No interest bearing funds has been invested for earning the exempted income. As the investment is made after the receipt of the sale proceeds of brand i.e. interest-free fund. The utilization of the interest-free fund is for investment. Therefore the interest bearing fund has not been utilized for .....

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fully gone through the terms of the agreement, whereas per clause (3), the company had during the year sold two of its brand groups Anafortan and Cefi for consideration of ₹ 115,88,77,800/-. This includes ₹ 91,00,000/- as know How Fee and ₹ 1,00,00,000/- towards Non Compete Fee. After adjusting ₹ 170,79,000/- for legal and professional services the balance of ₹ 112.26,98,800/- which was a receipt of Capital Nature was transferred to Reserve and Surplus A/c. The Non .....

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wards trade-marks, knowhow fee and non-compete fee. It is also relevant to mention here that a similar nature of sale of brand was made by assessee in A.Y. 2000-01 wherein the assessee had treated the sale of brand as income from capital gain and the treatment given by assessee was upheld by the Hon'ble Tribunal in assessee's own case for A.Y. 2000-01 vide order dated 15.3.2007. Accordingly no fault can be found in AO’s order treating the sale proceeds of brand as capital receipts liable to tax .....

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ity for offering the tax on sale of brands as LTCG. There is no merit in CIT’s observation for treating the same as business income. - Claim of clinical support expenses - Held that:- Whatever the separate expenditure are incurred by the assessee was in relation to gather the data making aware of the product of the company and remaining in the market. From the order of CIT we observe that no where the CIT has pointed out as to how the treatment given by assessee was erroneous, i.e. not as pe .....

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ceedings. Since the AO was satisfied with the details furnished by assessee vide letter dated 15.12.2011, no addition was made by the Assessing Officer on account of clinical support expenses. - Applicability of the provisions of section 94(7) and 94(8) on sale of shares/mutual funds - Held that:- Short Term Capital Loss incurred when units (and not shares) are purchased within 3 Months prior to the date on which additional units are allotted and subsequently are sold within 9 Months after .....

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pplicable as shares are purchased & sold. - From the record we also found that during the course of original assessment proceedings, complete details were given to the Assessing Officer with regard to working of capital gains on sale of shares and units. On perusal of the said details, it can be seen that the assessee purchased units on 19.09.2008 and sold the same on 26.12.2008. The dividend on the said units was declared on 26.12.2008. Thought the units were sold within nine months from th .....

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Hon'ble Supreme Court in case of CIT vs. Walfort Shares and Stock brokers Ltd (2010 (7) TMI 15 - SUPREME COURT) wherein eld by Supreme Court that mere tax planning without any motive to avoid taxes is not a colourable device. No merit in CIT’s direction for applying provision of section 94(7) and 94(8) of the IT Act for disallowing loss incurred on L & T shares. - I.T.A. No. 2765/Mum/2014, I.T.A. No. 2702/Mum/2014 - Dated:- 23-6-2016 - SHRI R. C. SHARMA, ACCOUNTANT MEMBER AND SHRI AMARJIT SINGH, .....

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der passed by the Ld. Commissioner of Income tax is bad in law, void ab initio without jurisdiction as the order u/s. 263 is passed by the Ld. CIT on the basis of audit objection memo dt: 02/04/2013. 2. On the facts and circumstances of the case, the order passed u/s 263 of the Act by Ld. CIT may be quashed and set aside on the ground that the Ld. CIT did not consider the argument taken by the appellant that the order passed by the AO u/s 143(3) is neither erroneous nor prejudicial to the intere .....

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g: o STT expenses of ₹ 19.42,671/-[for disallowance U/S 14A vis-à-vis Rule 8D] o Interest expenses of ₹ 2,00,83,931/- for disallowance u/s 14A vis-a-vis Rule 8D (Net of interest received). o sale of brands for ₹ 115,88,77,800/- o Delayed payment of PF and ESIC of ₹ 27,79,2711- [employees' contribution]. o Clinical support expenses ₹ 186,72,348/- o Applicability of Sec.94(7) and 94(8) on sale of shares/mutual fund o Computation of profit u/s 115JB of the A .....

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appellant that the order passed by the Assessing Officer u/s 143(3) is neither erroneous nor prejudicial to the interest of the revenue. 2.1 That on all the issues raised by the ld CIT, a possible view has been taken by the Assessing Officer while passing the order u/s 143(3). Hence neither the order is prejudicial nor erroneous to the interest of revenue. 2.2 The Ld CIT ought to have held that the order passed by the AO was neither erroneous nor prejudicial of the interest of Revenue in respect .....

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ssee is engaged in manufacturing of pharmaceutical drugs and molecules. After assessments were completed u/s.143(3), the CIT invoked his jurisdiction u/s. 263. During the course of proceedings u/s. 263, the CIT observed that the assessee has incurred STT expenses to the tune of ₹ 19,42,671/-. This has been debited under the head "Miscellaneous expenses". No enquiry has been carried out in this regard. The bifurcation of miscellaneous expenses is available on record but these deta .....

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ss on L& T shares and also profits from F&O Transactions. Even for working out disallowance u/s 14A r.w Rule 8D pertaining to exempt income the AO ought to have gathered these basic details. The disallowance under the head "Direct expenses" under Rule 8D hinged upon collecting this vital information. If this information was not there A.O ought to have considered entire amount of STT (Rs.19,42,671/-) as direct expenses for disallowance u/s 14A r.w Rule 8D of the Act. 4. In respe .....

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empt income was also highly relevant enquiry. The disallowance u/s 14 A r.w. Rule 8D cannot be worked out in absence of these basic details. 5. With regard to netting of interest, the CIT observed that the A.O also worked out "net interest" paid for working out disallowance u/s 14A. This is highly debatable. There is nothing on record to justify adopting this methodology. The A.O. it seems simply went by version of assessee. 6. With respect to the sale of brands the CIT observed that t .....

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for ₹ 113.97 crores. The A.O. ought to have verified whether relevant registration of Copy Right and Trade Marks with the office of Controller General of Patents, Designs & Trademarks(CGPDTM) has been done or not. It is difficult to believe that such important Intellectual Property Rights would be allowed to remain unprotected from copy right and trade mark infringement. If these are registered trademark or registered under the Copy Right Act then the consideration for assignment of T .....

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equired to examine the claim of the assessee that these brands/trade marks were generated/developed by the assessee itself and not purchased by verifying with respect to expenditure incurred in the earlier years for registration of Trade Marks and Copy Right brand building and whether these were claimed as revenue expenditure or treated as capital expenditure. Without making any relevant inquiry the AO accepted the claim of the assessee. 7. With regard to the expenses incurred on clinical suppor .....

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d by pharmaceutical companies which is in the nature of freebees given to / enjoyed by medical practitioner or professional associations The AO has allowed the expenditure of ₹ 1,86,72.348/- without verifying what sort of expenditure has been incurred under this head. 8. With regard to the deduction claimed on account of payment of PPF/ESIC, the CIT observed that the AO also allowed deduction of ₹ 27,79,271/- being delayed payment of PPF/ESIC. The AO ought to have considered the fact .....

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ssue was not covered u/s 43B of the Act. 9. With regard to the sale of L & T shares, the CIT observed that the sale of L & T shares immediately after declaration of bonus share was intend to reduce the taxable income and the AO has failed to examine these aspects. 10. The CIT also observed that the A.O has not worked out any profit u/s 115JB of the Act. It seems that A.O simply went by claim of the assessee in the footnote of the computation that working u/s 115JB of the Act has not been .....

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11. With respect to each and every quarry so raised by CIT as stated above, the assessee has filed detailed reply along with documentary evidence, however, being not convinced by the reply of the assessee, the CIT directed the A.O. to frame fresh assessment order. 12. The ld. AR argued that the A.O. after making the proper enquiry has made the relevant addition/disallowance. Merely because the A.O. has not reproduced each and every reply filed by the assessee and taken a conscious decision afte .....

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ced on record the order giving effect passed by the A.O. u/s. 143(3) r/w s. 263 to contend that the Assessing Officer has also not properly appreciated the direction of the CIT and blindly made the addition. 13. On merits it was argued by ld. AR that issue with regard to disallowance of interest u/s.14A, when the assessee is having sufficient interest free funds is squarely covered by the decision of jurisdictional High Court in the case of Reliance Utilities, 178 taxmann 135. Accordingly no inf .....

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not disallowing interest. 14. With regard to sale of brand being treated by CIT(A) as business receipts, it was contended by ld. AR that issue is covered in favour of the assessee by the order of the Tribunal in assessee s own case for assessment year 2000-2001, order dated 1st March, 2007, wherein the Tribunal held that profit on sale of brand is capital receipt and not business receipt. As per ld. AR in view of the decision of Tribunal in assessee s own case decided in its favour and revenue .....

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as held that CBDT Circular for disallowance of clinical support expenses is applicable from assessment year 2013-2014 and since the relevant assessment years are 2009-2010 & 2010-2011, no disallowance can be made by taking the help of this Circular. In view of the decision of coordinate bench, ld. AR argued that the view taken by the AO is one of the plausible view and cannot be said to be erroneous. 16. On the other hand, the ld. DR relied on the order of the CIT passed u/s. 263 and contend .....

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y the assessee before the A.O. during the original assessment proceeding as well as before the CIT in reply to quarries so raised by him while passing the order u/s. 263 respectively. We have also considered judicial pronouncements cited by ld. AR and ld. DR during the course of hearing before us, with reference to the factual matrix of the case. 18. From the record, we found that in the audit conducted by the internal audit party on 02.04.2013, certain objections were raised in as much as, acco .....

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utation of book profits. Armed with the report of the audit party, the Commissioner of Income-tax issued a notice u/s. 263 of the Act setting aside the assessment completed u/s. 143(3) of the Act and directing the AO to re-do the same de novo on the aforesaid issues. Rejecting the objections filed, the CIT passed his order u/s. 263 of the Act on 31.03.2014. In this order the CIT directed the Assessing Officer to examine: i) whether STT expenses were incurred on F & O transactions or sale of .....

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v) applicability of the provisions of S. 94(7) and 94(8) of the Act on sale of shares/mutual fund; and vi) the computation of profit u/s. 115JB of the Act. 19. From the record we found that the A.O. has disallowed a sum of ₹ 7,65,641/- u/s.143(3) order as per rule 8D u/s.14A. The STT paid of ₹ 19,42,671/- is against the derivative (F & O) transactions and purchase and sale of shares - the break up is as under: F & O ₹ 4,63,247/- Sale and purchase of shares Rs.14,79,424 .....

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n it is to be reduced from the computation of the capital gain being direct expenditure for earning the capital gains. Therefore disallowance under this section is not prejudicial to the interest of revenue being no tax effect. Accordingly, there is no justification for the direction issued by CIT for disallowance of STT u/s. 14A. 20. With regard to CIT s direction for disallowance interest, we found that the assessee company has paid interest of ₹ 2,00,83,931/- which has been debited to P .....

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annot be faulted by CIT. From the record, we also found that during the year the interest paid on the loans taken was for the purpose of business activities on bank overdraft limit. Interest was received on the deposits from the customers, from shareholders and directors and the bank commission is for other charges and not any expenditure was incurred for earning the exempted income. 21. We also found that as per balance-sheet placed on record investment as on 31/3/09 is ₹ 15,91,91,128/-. .....

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available with the company by way of share capital and reserves & surplus which stood at ₹ 89.75 crores as on 31/3/09. 22. As per the decision of Bombay High Court in the case of Reliance Utility reported in 178 Taxman 135 whereby if the company's funds are interest free more than the investments the question of disallowing interest u/s.14A does not arise. Accordingly there is no merit in CIT s order directing disallowance of interest u/s. 14A. In view of the sufficiency of own fun .....

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fered the same as long term capital gains. The objection of the CIT was that instead of charging the capital gain the said sum should have been taxed as business income. 24. We had carefully gone through the terms of the agreement, whereas per clause (3), the company had during the year sold two of its brand groups Anafortan and Cefi for consideration of ₹ 115,88,77,800/-. This includes ₹ 91,00,000/- as know How Fee and ₹ 1,00,00,000/- towards Non Compete Fee. After adjusting & .....

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iod of time and in fact they are not stock-in-trade of company. The company does not deals in the brands as a traders. 25. Provisions of section 55(2)(e) which deals with the computation of income from capital gains reads as under: a) in relation to a capital asset, being goodwill of a business [or a trade mark or brand name associated with a business] [or a right to manufacture, produce or process any article or thing] [or right to carry 011 any business], tenancy rights, stage carriage permits .....

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legal position where apparatus of the business is sold, it is the sale of capital asset and not stock-in-trade. As per the provisions of the Act as existed prior to 1995 where the cost of the acquisition could not be ascertained in the case of goodwill , trade mark, or brand the same was not taxable but the legislature in its own wisdom taxed the sale of brand etc as capital gain u/s. 55(2) of the Act. Thus, the assessee has correctly offered the tax on sale of brand as LTCGs insofar as brands .....

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lso found that all the agreements were placed before the CIT. The assessee has also filed submission before the CIT to justify the value assigned towards trade-marks, knowhow fee and non-compete fee. It is also relevant to mention here that a similar nature of sale of brand was made by assessee in A.Y. 2000-01 wherein the assessee had treated the sale of brand as income from capital gain and the treatment given by assessee was upheld by the Hon'ble Tribunal in assessee's own case for A.Y .....

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rected the Assessing Officer, without satisfying himself, to verify whether the bifurcation made by assessee was with a view to reduce tax or not. 27. In view of the above, we do not found any infirmity for offering the tax on sale of brands as LTCG. There is no merit in CIT s observation for treating the same as business income. We direct accordingly. 28. With regard to the claim of clinical support expenses, from the details filed before CIT, we found that these expenses are incurred while lau .....

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ouncil of India as referred by the CIT speaks about the gift, travel facility, hospital, money granted however none of these facilities are given by assessee. In fact, whatever the separate expenditure are incurred by the assessee was in relation to gather the data making aware of the product of the company and remaining in the market. From the order of CIT we observe that no where the CIT has pointed out as to how the treatment given by assessee was erroneous, i.e. not as per law and as a resul .....

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AO was satisfied with the details furnished by assessee vide letter dated 15.12.2011, no addition was made by the Assessing Officer on account of clinical support expenses. 29. With regard to the explanation to S. 37(1) of the Act, the CIT has nowhere pointed out as to how the said explanation will be applicable to the assesse. In so far as the direction issued to disallow the said payment on the basis of Circular No. 5/2012 (F. No. 225/142/2012-ITAII) dated 01.08.2012 issued by the Income Tax D .....

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ion are A.Ys. 2009-10 and 2010-11. Accordingly, the circular is not applicable to the years under consideration which has been made applicable only from A.Y. 2013-14 only. Thus there is no merit in CIT s direction for disallowing clinical support expenses. 30. Now coming to the applicability of the provisions of section 94(7) and 94(8) on sale of shares/mutual funds. 31. We have considered the rival contentions and found that the capital loss arising out on sale of L & T shares was treated b .....

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94(8) we reproduce the same as under: (8) Where - (a) any person buys or acquires any units within a period of three months prior to the record date; (b) such person is allotted additional units without any payment on the basis of holding of such units on such date; (c) such person sells or transfers all or any of the units referred to in clause (a) within a period of nine months after such date, while continuing to hold all or any of the additional units referred to in clause (b), then, the los .....

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erest" includes a dividend; (aa) "record date" means such date as may be fixed by- (i) a company for the purposes of entitlement of the holder of the securities to receive dividend; or (ii) a Mutual Fund or the Administrator of the specified undertaking or the specified company as referred to in the Explanation to clause (35) of section 10, for the purposes of entitlement of the holder of the units to receive income, or additional unit without any consideration, as the case may be .....

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in clause (b) of the Explanation to section 115AB. As per the above section, Short Term Capital Loss incurred when units (and not shares) are purchased within 3 Months prior to the date on which additional units are allotted and subsequently are sold within 9 Months after the date while holding on to all or any of the additional units allotted, is not to be allowed to the extent of the market value of the additional units as on the date they are allotted. Units as referred to in the above sectio .....

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ction 94(7) as under: "(7) Where- (a) any person buys or acquires any securities or unit within a period of three months prior to the record date; (b) such person sells or transfers- (i) such securities within a period of three months after such date; or (ii such unit within a period of nine months after such date; (c) the dividend or income on such securities or unit received or receivable by such person is exempt, then, the loss, if any, arising to him on account of such purchase and sale .....

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of the Dividend received on those Shares/Units. However in the assessee's case, though the Units are sold within 9 Months from the date on which Dividend is received, the same were purchased (19/9/2008) beyond 3 months prior (27/9/2008) to the date of declaration of dividend (26/12/2008). Therefore the provisions of section 94(7) are not applicable as both the conditions must be satisfied together for the provisions to apply. In assessee s case the purchase is prior to 3 months from the rec .....

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received, since they were purchased more than three months prior to date of declaration of dividend, the provisions of S. 94(7) of the Act will not apply. 35. With regard to CIT s observation regarding loss incurred on sale of L & T shares, though the CIT agrees that the provision of section 94(8) will not apply to the shares. The assesse is free to carry out tax planning within the provisions of law. A similar argument was raised by the department before the Hon'ble Supreme Court in cas .....

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d ESI and computation of book profit u/s. 115JB was not pressed by the ld. AR, the same are therefore dismissed in limine as not pressed. 38. In the result, the assessee s appeal for A.Y. 2009-10 is allowed in part in terms indicated hereinabove. ITA No. 2702/Mum/2014 (A.Y. 2010-11) 39. In this order also the CIT has alleged for disallowance STT expenses and disallowance of interest under Rule 8D, clinical expenses and capital gains and sale on land and building. 40. We have considered the rival .....

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1. In course of the ensued proceedings, a revised computation declaring a loss of ₹ 46,21,76,813/- was filed as it was noticed that while calculating long term capital gain on sale of land, inadvertently, no indexation was claimed on the cost of land. Whatever details and/or information were requisitioned for completion of the assessment were duly submitted which fact has also been acknowledged by AO in the order dated 20.03.2012 passed u/s, 143(3) of the Act, wherein the loss was determin .....

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med with the report of the audit party the CIT passed order u/s. 263 dated 31.3.2015. The CIT, in his order passed u/s. 263 of the Act, directed the Assessing Officer to examine: i) whether STT expenses were incurred on F & O transactions or sale of L&T shares. ii) whether there was direct use of borrowed funds by the assessee for purpose of investment in shares. iii) the nature of expenses incurred under clinical support services. iv) the computation of capital gain with regard to the & .....

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essing Officer also examined the issue of disallowance u/s 14A r.w.r. 8D of the Act. While computing disallowance of direct expenditure incurred for the purpose of investment as per Rule 8D(2)(i), the Assessing Officer again considered the said amount of STT paid leading to double disallowance of the same amount i.e. i) Disallowance of STT in the main computation of income ii) Disallowance of STT while computing disallowance u/s 14A r.w.r 8D of the Act by considering such amount as direct expens .....

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f the assessee was sufficient to cover up the value of the investments, hence no interest disallowance can be made as per the decision of Hon'ble jurisdictional High Court in the case of CIT vs. HDFC Bank 366 ITR 505 and Reliance Utility reported in 178 Taxman 135. We direct accordingly. 44. With regard to the disallowance of clinical support expenses, as per the reasoning given in A.Y. 2009-10, we do not find any merit for applying the CBDT Circular No. 5/2012 dated 01.8.2012 to the A.Y. 20 .....

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