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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 ..... nditure. We notice that the assessee has held units in ICICI prudential Liquid fund to the tune of 2.60 crores as at the beginning of the year and the same has been sold during the year under consideration. Further, during the year under consideration, the assessee has also made fresh investment of 10 lakhs in its subsidiary named M/s Clinigene International Ltd. The assessee 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, could not have been undertaken without using the establishment of the assessee. Not be practicable to apply provision of Rule 8D(2)(iii) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e provisions of sec. 14A of the Act are attracted and accordingly worked out disallowance u/s 14A by applying provisions of Rule 8D. The AO disallowed interest expenses under Rule 8D(2)(ii) of the Rules at ₹ 2,42,930/- and further made disallowance out of administrative expenses under Rule 8D(2)(iii) at ₹ 65,498/.- In aggregate the AO disallowed a sum of ₹ 3,08,428/- u/s 14A of the Act. The ld CIT(A) confirmed the same and hence the assessee has filed this appeal 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g reliance on the coordinate bench decision rendered in the case of Biocon Research Ltd., Vs. Addl. CIT (ITA Nos.1229 and 1329/Bang/2016 dated 18/2/2017), submitted that the no disallowance u/s 14A is called for. 7. We have heard the ld DR on this issue and perused the record. From the financial statements, we notice that the assessee has held units in ICICI prudential Liquid fund to the tune of 2.60 crores as at the beginning of the year and the same has been sold during the year under consideration. Further, during the year under consideration, the assessee has also made fresh investment of 10 lakhs in its subsidiary named M/s Clinigene International Ltd. The assessee has also received dividend income of 114.95 crores durin ..... X X X X Extracts X X X X X X X X Extracts X X X X
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