TMI Blog2017 (12) TMI 1592X X X X Extracts X X X X X X X X Extracts X X X X ..... r analysing the decision but upholding the rejection of the disallowance by the AO offered by the assessee. The ITAT in the impugned judgment granted complete relief to the assessee - Held that:- entire exempt income in the present case was purely incidental, consequent of the deployment of surplus funds for a part of the period. The findings of the CIT (A) clearly point to the fact that the asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er ₹ 76 lakhs. The assessee was engaged in the business of power generation for which purpose it had partly borrowed amounts from public financial institutions. Consequently, it had to service the equipments/machinery. A portion of its funds were surplus which was invested during the ongoing industrial activity of setting up a plant. The income earned from such investment was exempt from ta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the opinion that the entire exempt income in the present case was purely incidental, consequent of the deployment of surplus funds for a part of the period. The findings of the CIT (A) clearly point to the fact that the assessee had utilised the entire borrowed funds for the purpose of setting up of its plan and undertaking the industrial activity. In these circumstances, the disallowance offer ..... X X X X Extracts X X X X X X X X Extracts X X X X
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