Dismissing the appeal of the revenue the Court held that the Assessing Officer had accepted that the assessee had not borrowed funds. The assessee had deducted certain proportionate expenditure, which the Assessing Officer had not disbelieved or disputed. Volume of investment, the assessee was said to have received charge-free services from banks and other financial institutions with whom it had invested. The Tribunal had correctly deleted the disallowance of Rs. 12.29 crores under section 14A of the Act in accordance with rule 8D of the Income-tax Rules.
CIT v. Sesa Goa Ltd (2021)436 ITR 17 / 203 DTR 97/ 321 CTR 113 (Bom.)(HC)
S. 14A : Disallowance of expenditure-Exempt income-Enhancement of disallowance is held to be not valid. [R. 8D]