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TMI Blog2019 (6) TMI 703X X X X Extracts X X X X X X X X Extracts X X X X ..... V Pradeep Kumar, Addl. CIT ORDER PER B.R BASKARAN, ACCOUNTANT MEMBER The appeal filed by the assessee is directed against the order dated 14/3/2018 passed by ld CIT(A)-6, Bengaluru and it relates to asst. year 2012-13. 2. The assessee is aggrieved by the decision of ld CIT(A) in confirming the disallowance made by the AO u/s 14A of the Act. 3. The assessee is engaged in the business of manufa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al before us. 4. The ld AR placed reliance on the decision rendered by the Hon'ble Bombay High Court in the case of Reliance Utilities and Power Ltd., 313 ITR 340 and submitted that the assessee is having own funds in excess of the value of investments and hence no disallowance out of interest expenditure is called for. 5. We have gone through the financial statement furnished by the assessee an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... see has made a investment only in units of mutual fund and dividend was earned from out of mutual funds only. The ld AR further submitted that the mutual fund has not charged any amount towards expenses upon the assessee and further the assessee has also not incurred any expenditure for earning the dividend income. The ld AR further submitted that the AO has not recorded his dissatisfaction over t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssee has also received dividend income of 114.95 crores during the year under consideration. Thus, we notice that there has been certain amount of activities in the investment portfolio of the assessee. The above said activities, in our view, could not have been undertaken without using the establishment of the assessee. However, in the facts and circumstances of the case, we are of the view that ..... X X X X Extracts X X X X X X X X Extracts X X X X
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