TMI Blog2019 (4) TMI 190X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee has incurred expenditure to earn exempt income. In the present case, we find that it is not a whisper but a categorical finding and satisfaction of the A.O. that expenditure has been incurred to earn the exempt income. In our considered opinion, the CIT(A)’s finding to this effect is devoid of any infirmity. Except for calling the categorical satisfaction of the A.O., absence of satisfaction, the ld. Counsel of the assessee has not made out any case to negate the disallowance u/s. 14A. Hence, in the background of the aforesaid discussion, we do not find any infirmity in the order of the authorities below. Hence, we uphold the same. - Decided against assessee. - ITA No. 329/Pan./2017 - - - Dated:- 15-1-2019 - Shri Shamim Y ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d submitted following : The assessee is in the business of extraction of iron ore. The surplus funds of the business are generally kept with the banks. The assessee is approached by number of mutual fund managers to make investments in respective mutual funds. In order to keep good relation with banks and financial institution and to effectively use the funds of business, the assessee has invested a small portion of funds of the business in -mutual funds as per the advice of such mutual fund managers. The said mutual fund officials come to the door step of the assessee and collect the forms and cheques and render all the services at the door step of the assessee. Except issuing of cheques in favour of the fund and accounting of the sta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unt of interest included in clause (i) incurred during the previous year - Nil B The average of value of investment, income from which does not or shall not form part of the total income appearing in the balance sheet of the assessee on the first day and the last day of the previous year - Nil C The average of total assets as appearing in the balance sheet of the assessee, on the first day and the last day of the previous year; Nil iii) an amount equal to one-half per cent of the average of the value of investment, income from which does not or shall not form part of the total income, as appearing in the balance sheet of the assessee, on the first day and the last day of the previous year. Opening Investment : ..... X X X X Extracts X X X X X X X X Extracts X X X X
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