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TMI Blog2021 (8) TMI 1321X X X X Extracts X X X X X X X X Extracts X X X X ..... ently followed for last eight years. Same was accepted by the revenue without any objection. The only issue is with respect to how the profit of the business for the purpose of long term housing finance shall be worked out. The only issue is that assessee is computed with respect to the total income with respect to the interest income whereas the Id AO has applied the above ratio to the total receipt. When the method has been consistently accepted for the above year we do not find any reason to defer from that. In view of this we do not find any infirmity in allowing the assessee claim of deduction u/s 36(1 )(viii) of the Act applying the ratio of 62.75%. In the result we do not find any merit in ground No. 1 of the appeal. Disallowa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d 27.06.2017 passed by the Commissioner of Income Tax (Appeals)-38, New Delhi ( Ld. CIT(A) ) for the assessment year 2014-15 in the case of PNB Housing Finance Ltd., ( the assessee ), the Revenue preferred this appeal. The assessee has also preferred cross objections in this appeal. 2. Brief facts of the case are that the assessee is an approved housing finance company engaged in the business of providing housing loans to individuals and body corporate for construction, purchase and upgradation of houses. For the assessment year 2014-15, they filed their return of income on 29.11.2014 declaring an income of Rs.1,43,38,89,780/- and revised the same on 29.03.2016 declaring income of Rs.1,45,07,34,980/-. Income of the assessee was, however, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by the coordinate Bench of this Tribunal in ITA No. 2123/Del/2015 and batch of cases and granted relief. The coordinate Bench, on this aspect, observed thus : 16. We have carefully considered the rival contentions. The appellant is a subsidiary of Punjab National Bank and is engaged in the business of retail lending and also offers long term finance for construction of homes. The assessee the business income of Rs. 876230348/- before deduction u/s 36(1)(viii) of the Act. Subsequently, assessee claimed deduction stating that Rs. 2817156893/- was on account of total interest on housing loans and out of it Rs. 1767869838/- was on account of interest on long term housing loan. Thus assessee stated that 62.75% in on account of interest on l ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uphold the findings of the ld. CIT(A). Hence, ground No. 1 of the Revenue s appeal is dismissed. In so far as the addition of Rs.3,87,94,000/- by invoking the provisions of section 14A read with Rule 8D is concerned, it is the finding of fact by the ld. CIT(A) that no dividend was earned by the assessee on the investment of Rs.79261.48 lakhs appearing as opening balance as on 01.04.2013 and investment of Rs.75914.59 lakhs appearing as closing balance considered by the Assessing Officer. Learned CIT(A) followed the binding precedent in the case of Joint Investments (P)Ltd. vs. CIT, 372 ITR 694 and deleted the addition. It is not established before us that the finding of fact by the ld. CIT(A) is in any way wrong. We, therefore, are of the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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