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TMI Blog2014 (11) TMI 553X X X X Extracts X X X X X X X X Extracts X X X X ..... ld that:- The Tribunal rightly observed that the amount of interest on borrowings for purchase of shares has to be deducted from the gross total income - The decision rendered in the case of Distributors (Baroda) Pvt. Ltd vs. Union of India & Others [1985 (7) TMI 1 - SUPREME Court] was considered by the Tribunal wherein it is held that the deduction required to be allowed u/s 80M has to be calcula ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dabad Bench (ITAT) in Income Tax Appeal No. 5748/Ahd/1991 for the assessment year 1985- 86, the revenue has preferred the present tax appeal raising the following substantial question of law: "Whether the Apellate Tribunal is right in law and on facts in treating the investment of ₹ 10,49,72,000/- as having been made by the assessee from his own funds for granting relief under Section 80M ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (A) and after considering submissions of both the sides, CIT(A) directed the AO to deduct the amount of interest attributable to the investments which came to ₹ 6,73,863/- from the dividend revceived by the assessee from domestic companies and compute the deduction u/s 80M on the net amount. 2.2 Being aggrieved by the order of the first appellate authority, the revenue preferred appeal befo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ly held in favour of the respondent. He submitted that the present appeal lacks merits and therefore deserves to be dismissed. 5. We have heard learned advocates for both the sides and perused the orders passed by the CIT as well as the Tribunal. The Tribunal in the impugned judgment and order has observed that the amount of interest on borrowings for purchase of shares has to be deducted from th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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