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TMI Blog2019 (7) TMI 355X X X X Extracts X X X X X X X X Extracts X X X X ..... een shown at ₹ 42,08,954/- as on 31.3.2012, but her investments are more than this. Her total investment was at ₹ 1,33,52,645/-. Against immovable properties she has shown investment of ₹ 9,98,150/-. Now what are these immovable properties, is not ascertainable, and what is the source of these, is also not identifiable. Her interest free fund is far less than the investment, and therefore, AO has rightly haboured a belief that interest expenses required to be calculated on the investment made by the assessee. One of the arguments raised by the assessee before the ld.Revenue authorities was that since she was in the business of trading in shares and securities, therefore, no disallowance out of interest expenditure is to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... RAJPAL YADAV, JUDICIAL MEMBER: The ld.CIT(A) has decided two appeals of the assessee for the Asstt.Years 2012-13 and 2014-15 by way of separate orders passed on 9.1.2018. The assessee is challenging both these orders in the present appeals. Sole grievance of the assessee is that the ld.CIT(A) has erred in confirming the addition of ₹ 76,614/- and 84,825/- which were added by the AO under section 14A of the Income Tax Act, 1961 read with Rule 8D of the Income Tax Rules, 1962. 2. Facts on all vital points are common in both the years. Therefore for the facility of reference we take up the facts mainly from the Asstt.Year 2011- 12. 3. The assessee is an individual at the relevant time ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ar 2012-13: Respected Sir, Reg: I.T.A. No.638 /AHD/2018 for Assessment Year 2012-13 in the matter of Shilpa Ajaykumar Parasrampuria Sub: Written Submission With reference to the above captioned subject, we plea for the following points:- 1. Addition of PPF Interest amounting to ₹ 29,989/-. We have received PPF maturity amount of ₹ 6,27,595/- as on 08.11.2011. ( Refer page No. 36) The PPF maturity passbook also mentioned amount of ₹ 6,27,595/-.(Refer page no. 36) The bank statement of PPF deposit is attached herewith :- Date Type of transaction ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... clear from our own capital. Hence addition on account of this may be deleted. Asstt.Year 2014-15: Respected Sir, Reg: I.T.A. No.640/AHD/2018 for Asst. Year 2014-15 in the matter of Shilpa Ajaykumar Parasrampuria Sub: Written Submission With reference to the above captioned subject, we plea for the following points:- 1. The Applicant had earned transport allowance amounting of ₹ 9600/- during the year, which is mentioned in Part-B of Form No.l6.(Refer page no. 46) 2.The same is exempt income, which was shown as deduction from Gross salary in Statement of Income.(Refer page no. 6) 3. T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... investment of ₹ 9,98,150/-. Now what are these immovable properties, is not ascertainable, and what is the source of these, is also not identifiable. Her interest free fund is far less than the investment, and therefore, the ld.AO has rightly haboured a belief that interest expenses required to be calculated on the investment made by the assessee. One of the arguments raised by the assessee before the ld.Revenue authorities was that since she was in the business of trading in shares and securities, therefore, no disallowance out of interest expenditure is to be made. This aspect has been settled in the decision of Hon ble Bombay High Court in the case of Godrej Boyce vs. CIT, 328 ITR 81 as well as in the case of Maxopp Investment Lt ..... X X X X Extracts X X X X X X X X Extracts X X X X
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