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2017 (8) TMI 661

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..... than investments. It was observed that the Assessee had sufficient interest free funds to cover the investment. The balance sheet shows that the Assessee has interest free funds amounting to ₹ 14,88,38,332/and the investment of ₹ 9,71,56,751/, which shows that the Assessee was having sufficient interest free funds to make the investment. Considering the factual matrix of the presen .....

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..... e Act read with Rule 8D. It deleted the disallowance by linking investment to the source of funds for the purpose of excluding interest expenditure from the consideration under Section 14A read with Rule 8D, without appreciating that no such exercise is envisaged in the method of computation prescribed in Rule 8D of the Income Tax Rules. 3] The learned counsel for the Respondent relies on the j .....

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..... ows that the Assessee was having sufficient interest free funds to make the investment. 5] Considering the factual matrix of the present case, the judgment of this Court in Commissioner of Income Tax vs. Reliance Utilities and Power Ltd. (supra) would squarely apply. The Tribunal has not committed any error in applying the said judgment. 6] In the light of the above, no substantial question .....

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