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TMI Blog2011 (1) TMI 1466X X X X Extracts X X X X X X X X Extracts X X X X ..... PER C.L.SETHI, JM : This is an appeal, filed by the assessee, directed against the learned CIT(A) s order dated 19.3.2010, pertaining to the AY 2003-04. 2. The various grounds of appeal raised by the assessee are directed against CIT(A) s order in confirming the ad-hoc disallowance of ₹ 87,170/- made by the AO on account of alleged expenditure presumed to have been incurred for ea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he assessee in the year on account of investment made earlier in RBI tax free relief bonds. However, the AO stated that no income can be derived without incurring any expenses. AO further observed that the assessee had made investment of ₹ 1,04,00,000/- in RBI tax free relief bonds and must have incurred expenses on account of bank charges and bank interest. AO, therefore, disallowed the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the AY 2002-03 i.e. in the immediately preceding assessment year. The assessee has computed the interest thereupon at the rate of 8.50%. The assessee has also made investment of ₹ 4 lakhs on 3.4.2002 and 1.11.2002 i.e. during the current financial year on which interest at the rate of 8% and 7% respectively has been shown to have been accrued. The assessee has worked out the total interest ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tax free relief bonds, the question of estimating the reasonable expenditure for the purpose of earning interest does not arise. We, therefore, delete the disallowance estimated by the AO and further confirmed by the learned CIT(A). Before parting with the matter, we may observe that the decision of Special Bench in the case of Daga Capital Management (P) Ltd. (supra) has been reversed by the Hon ..... X X X X Extracts X X X X X X X X Extracts X X X X
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