Held that the assessee had to establish by necessary fund flow statements that borrowed funds on which interest paid were not utilised for the purpose of making investments which yielded tax-free income. Disallowance was affirmed. (AY. 2009-10, 2010-11)
Karnataka State Beverages Corporation Ltd. v. ACIT (2022) 99 ITR 325 (Bang) (Trib)
S. 14A : Disallowance of expenditure-Exempt income-Failure to demonstrate that borrowed funds on which interest paid was not utilised for making investment-disallowance was affirmed. [R.8D(2)]