Tribunal held that there were sufficient interest-free funds in the form of share capital and reserves available with the assessee to explain the investment in mutual funds. In view of there being no interest expenditure relatable to the investment in the assets yielding exempt income, no disallowance could be made. CIT v. Reliance Utilities and Power Ltd. (2009) 313 ITR 340 (Bom) (HC) followed . Tribunal held that In the absence of any bifurcation of the expenses, a reasonable estimate had to be made for such disallowance. The Assessing Officer was to restrict the disallowance at 0.5 per cent. of the value of assets which had yielded exempt income. ACB India Ltd. v. ACIT (2015) 374 ITR 108 (Delhi)(HC) ACIT v. Vireet investment (P) Ltd. (2017) 58 ITR (Trib) 313(SB) (Delhi) [Trib) followed. (AY.2007-08, 2008-09)
ACIT v. Niit Technologies Ltd. (2020)79 ITR 60 ( Delhi) (Trib)
S. 14A : Disallowance of expenditure – Exempt income – Sufficient interest free fund – No disallowance can be made – Administrative expenses – No bifurcation of expenses – Disallowance at 0.5 Per Cent. is held to be a reasonable estimation.[ R.8D ]