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TMI Blog2011 (3) TMI 1717X X X X Extracts X X X X X X X X Extracts X X X X ..... h is a company engaged in the business of investment and finance. We are concerned with the assessment year 2006-07. 2. Though there are five grounds of appeal with several sub-grounds, the only effective issue is whether the departmental authorities have rightly invoked section 14A of the Income Tax Act, 1961, in disallowing a part of the interest paid by the assessee as having been incurred i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ome and borrowed funds and the investments made by the assessee in the aforesaid paragraph. The owned sources amounted to ₹ 89.00 crores and borrowed funds amounted to ₹ 5.00 crores. The investment during the year was ₹ 97.00 crores. Even going by these figures and applying the presumption laid down in the aforesaid judgment, the investment to the extent of ₹ 89.00 crores s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... terest of justice, to restore the matter to the file of the Assessing Officer, who shall take a fresh decision with regard to the applicability of section 14A of the Act in respect of the interest after giving adequate opportunity of being heard to the assessee. We also make it clear that the Assessing Officer shall not invoke Rule 8D of the Income Tax Rules which has been held to be applicable on ..... X X X X Extracts X X X X X X X X Extracts X X X X
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