TMI Blog2018 (2) TMI 1652X X X X Extracts X X X X X X X X Extracts X X X X ..... (8) TMI 119 - BOMBAY HIGH COURT] wherein it has been held that where the Assessee has its own funds, no occasion to disallow any part of interest payment made by the Assessee under Section 14A can arise. Further, we also note that the Assessing Officer has not recorded his non-satisfaction with the claim for disallowance made by the Respondent before proceeding to apply Rule 8D of the Rules. Furt ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in the circumstance of the case and in law, the Tribunal was justified in not confirming the disallowance of ₹ 60,24,063/u/ s. 14A of the I.T. Act? 3 The Respondent is a nonbanking finance company. During the subject Assessment Year, it had received dividend income of ₹ 1.19 Crores which was exempted. The Respondent had disallowed 1% of the expenses as being attributable to earn ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... enhanced the disallowance from 1% of the expenses to 5% of the dividend income earned as expenditure to earn exempted income. 7 The grievance of the Revenue is that Rule 8D of the Rules ought to be applied in the facts of the present case. We find that the issue as raised by the Revenue is concluded against it by the decision of this Court in CIT v/s. HDFC Bank Ltd., 366 ITR 505 wherein it h ..... X X X X Extracts X X X X X X X X Extracts X X X X
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