TMI Blog2019 (4) TMI 502X X X X Extracts X X X X X X X X Extracts X X X X ..... DFC BANK LTD. vs. DEPUTY COMMISSIONER OF INCOME TAX [2016 (3) TMI 755 - BOMBAY HIGH COURT] held that in a situation where own funds or interest free funds exceeded the amount of relevant investment, it may be presumed that the investment was from own funds. Therefore, ld CIT(A) following the judgment of Bombay High Court in the case of HDFC BANK LTD (supra), deleted the addition. In respect of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ld. AR For the Respondent : Shri P.K. Mondal, JCIT/ld.DR ORDER PER BENCH: The captioned two appeals filed by the assessee, are directed against order dated 03-07-2018 passed by the ld. Commissioner of Income-tax (Appeals), Jamshedpur, which in turn arise out of an order passed by the Assessing Officer u/s. 143(3) of the Income-Tax Act, 1961 (in short, the Act). 2. Since th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee contended before the AO that no borrowed funds / interest bearing funds were deployed to acquire the assets from which exempt income was generated. During the course of assessment proceedings, the assessee made an argument that his own funds (Share Capital + Reserves Surplus) at ₹ 66.38 crores were far exceeding the relevant investment amount of ₹ 17.25 crores. However, the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vs. DEPUTY COMMISSIONER OF INCOME TAX 383 ITR 0529 (Bom), held that in a situation where own funds or interestfree funds exceeded the amount of relevant investment, it may be presumed that theinvestment was from own funds. Therefore, ld CIT(A) following the judgment of Bombay High Court in the case of HDFC BANK LTD (supra), deleted the addition. However, in respect of Rule 8D (2) (iii), we note ..... X X X X Extracts X X X X X X X X Extracts X X X X
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