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TMI Blog2019 (7) TMI 354X X X X Extracts X X X X X X X X Extracts X X X X ..... apital, reserves and surplus aggregating to ₹ 7,54,94,323/-, as against the investments of ₹ 4,26,14,226/-. Since, the assessee s own interest free funds are sufficient to cover the investments it is presumed that entire investments are made from non-interest bearing funds. The Hon ble Jurisdictional High Court in the case of Commissioner of Income Tax Vs. HDFC Bank Ltd. [ 2014 (8) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 012-13. 2. Mrs. Anita Singh appearing on behalf of the assessee submitted that the solitary issue raised in appeal by the assessee is with respect to disallowance made u/s. 14A r.w. Rule 8D(2)(ii) of the Act. The ld. AR submitted that the assessee is a private limited company engaged in the business of manufacture and sale of Inorganic and Micronutrient Mixture Fertilizers. The as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The ld. AR submitted that similar disallowance on account of interest expenditure u/s. 14A was made in assessment years 2008-09 and 2010-11. The issue travelled to the Tribunal. The Tribunal in ITA No. 638/PUN/2017 for assessment year 2008-09 decided on 28-09-2018 and ITA No. 137/PUN/2015 for assessment year 2010-11 decided on 18-10-2017 deleted the disallowance in respect of interest expenditure ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... authorities below perused. The assessee in appeal has raised single issue assailing disallowance of ₹ 12,08,801/- u/s. 14A r.w. Rule 8D(2)(ii) of the Act. The ld. AR has drawn our attention to the Balance sheet as on 31-03-2012 at page 7 of the paper book. A perusal of Balance sheet shows that the assessee is having own interest free funds comprising of share capital, reserves and surplus ag ..... X X X X Extracts X X X X X X X X Extracts X X X X
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