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TMI Blog2016 (1) TMI 1295X X X X Extracts X X X X X X X X Extracts X X X X ..... . O R D E R Per Sanjay Garg, Judicial Member: The above captioned two appeals by different but related assessees have been preferred against the separate orders of the Commissioner of Income Tax (Appeals) [hereinafter referred to as the CIT(A)] both dated 07.01.2013. Since the issue raised in both the appeals is common, hence the same were heard together and are being disposed of with this c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... me of Rs. 65,03,721/- during the year. Whereas the total interest of finance charges incurred by the assessee are at Rs. 5,01,612/-. The Ld. A.R. of the assessee has thus submitted that if the netting of the interest income and interest expenditure is done, then the assessee has earned a positive interest income during the year. He has, therefore, submitted that in view of the above, it cannot be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e had a net positive income, under such circumstances the disallowance of interest expenditure under section 14A was not warranted. 5. So far as the disallowance of administrative expenses is concerned, the Ld. A.R. has submitted that the investments made by the assessee in unquoted shares of the subsidiaries/sister concerns to gain control over the management was not liable to be included in the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... arlier assessment year. The strategic investments in group companies and sister concerns for having control over the management of the said companies are not intended for the purpose of earning of exempt income. Under such circumstances for computing the average value of investment for the purpose of disallowance under rule 8D(2)(iii), the investments made in unquoted shares of the subsidiaries si ..... X X X X Extracts X X X X X X X X Extracts X X X X
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