2017 (12) TMI 1641

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..... ecessarily held that once the appellant has earned substantial taxable income from investment in partnership firm and the Exempt Income earned being merely 3% of the substantial taxable income earned by the appellant the disallowance has to be made in the ratio of Exempt/Taxable income and accordingly, disallowance made under rule 8D has to be proportionately reduced. The disallowance made is here .....

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..... 14A of the Act from ₹ 31,98,441/- to ₹ 1,00,663/- while assessee has been made investment of interest bearing funds in the partnership firm, profit of which was exempt and; (2) restricting the disallowance under Section 14A of the Act from ₹ 31,98,441/- to ₹ 1,00,663/- by applying the ratio of 1:30:85 for exempt income and taxable income, whereas provision of Section 14A r. .....

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