COURT: | ITAT Mumbai |
CORAM: | Joginder Singh (JM), Sanjay Arora (AM) |
SECTION(S): | 14A, Rule 8D |
GENRE: | Domestic Tax |
CATCH WORDS: | exempt income |
COUNSEL: | Sanjay B. Sawant |
DATE: | November 17, 2014 (Date of pronouncement) |
DATE: | November 24, 2014 (Date of publication) |
AY: | 2009-10 |
FILE: | Click here to view full post with file download link |
CITATION: | |
S. 14A Rule 8D: No presumption can be drawn that investment in tax-free securities has come from own funds. The amount of disallowance has to be added to the book profits u/s 115JB |
(i) As regards the claim qua disallowance of interest expenditure, the argument of sufficient capital, so that the same must be presumed as having been applied toward investments yielding tax exempt income, misses the point completely. The matter has to …
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