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2022 (9) TMI 497 - ITAT DELHIDisallowance u/s 36(1)(iii) - Working of interest cost on investments - assessee had not shown any figure of interest pertaining to investments or capital work-in-progress - as per AO assessee has not established or pointed to the nexus of interest free funds being used for investments, he was of the view that fair and reasonable method was debt equity ratio for the purpose of reallocating the interest under various heads of income - HELD THAT:- We find that CIT(A) while deciding the issue in favour of the assessee has followed the decision of Tribunal in assessee’s own case for A.Y. 2010-11 [2016 (11) TMI 1360 - ITAT DELHI] We further find that thereafter, Co-ordinate Bench of Tribunal in assessee’s own case for A.Y. 2012-13 [2022 (3) TMI 1419 - ITAT DELHI] has decided the identical issue in assessee’s favour as held assessee had sufficient interest free funds to meet the capital expenditure and to make investments, no disallowance u/s 36(1)(iii). Before us, no distinguishing feature in the facts of the case and that of earlier years which have been decided by ITAT in assessee’s favour has been pointed out by Revenue. In such a situation, we find no reason to interfere with the order of CIT(A) and thus the ground of Revenue is dismissed.
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