9911796707
TMI Blog2024 (12) TMI 38X X X X Extracts X X X X X X X X Extracts X X X X ..... r Media Services Pvt. Ltd. vs DCIT [ 2023 (7) TMI 855 - ITAT MUMBAI] . Appeal of the assessee is allowed. - Shri Amarjit Singh, Accountant Member And Shri Sandeep Singh Karhail, Judicial Member For the Assessee : Shri Prakash Jotwani For the Revenue : Shri Ram Krishna Kedia, Sr. DR ORDER PER AMARJIT SINGH, ACCOUNTANT MEMBER: This appeal of the assessee for the assessment year 2020-21 is directed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that whether interest income is earned on current account or capital account is the same and disallowance u/s 14A is applicable towards interest earned on current account too. 2. Fact in brief is that return of income declaring total income of Rs. 83,86,110/- was filed on 25.01.2021. The case was subject to scrutiny assessment and assessment u/s 143(3) r.w.s. 144B of the Act was finalized on 13.0 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of profit from firms Rs. 31,78,502/- ii. Interest income from firms Rs. 41,79,891/- 5. The AO stated that share of profit from firms received at Rs. 31,78,502/- is exempt u/s 10(2A) of the Act. Therefore, the AO has determined the interest expenditure of Rs. 24,51,171/- relating to the income claimed as exempt u/s 10(2A) and added to the total income of the assessee. The assessee had made investm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t in the case of CIT vs HDFC Bank Ltd. (2014) 366 ITR 505 (Bom) and decision of the Hon ble Supreme Court in South India Bank Ltd. vs CIT (2021) 438 ITR 001 (SC) held that where assessee s own funds and other non-interest bearing funds were more than the investment in tax free securities no disallowance u/s 14A can be made. 7. The ld. Counsel also referred the decision of the ITAT Mumbai in the ca ..... X X X X Extracts X X X X X X X X Extracts X X X X
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