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TMI Blog2014 (8) TMI 1137X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee were only 35 crores. The ld. CIT(A) himself accepted that assessee is having sufficient own funds as capital as compared to investments yielding exempt income. In these circumstances we hold that since the assessee has sufficient own capital to make investment for earning exempt income no portion of interest from borrowed capital should be allocated to earn exempt income in this case. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... come Tax Rule, 1962. 2. That, without prejudice to the above, in the facts and circumstances of the case the learned CIT(Appeal) was wrong in confirming the disallowance of ₹ 17434539/- yu/s 14A of the Income Tax Act, 1961 as against the total exempt income of ₹ 1300000/- only. 3. That the appellant craves leave to modify/alter/add any grounds of appeal at or before hearing." 3. In ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rthermore, it was submitted that the assessee has raised loan funds for specific purposes which has been utilized for the said purposes. Hence no apportionment of this interest expenditure can be done for earning exempt income. However, the ld. CIT(A) was not convinced with the submissions of the assessee. He concluded as under :- "Therefore, in view of the above facts and circumstances that the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... itted that the loans obtained by the assessee were for the specific purposes and were utilized for the concerned purpose. Hence there is no question of allocation of this interest expenditure towards earning of interest income. The ld. Counsel of the assessee hence submitted that the assessee is disputing the allocation of 1,53,48,915/- being interest expenditure allocated for earning exempt incom ..... X X X X Extracts X X X X X X X X Extracts X X X X
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