Tribunal  held that  there were no borrowings made by the assessee in order to make payment of interest thereon. The interest paid by the assessee had no nexus or bearing with the investment in mutual funds and shares. The existence of the dispute and the copy of the order of the Commission was brought to the notice of the Commissioner (Appeals) and he had not made any disallowance under section 14A of the Act. Hence, there could not be any proportionate disallowance of interest in terms of second limb of rule 8D(2) of the Rules. Accordingly, the disallowance of interest was hereby deleted. As regards administrative expenses disallowance is attracted.  The period during which lockdown was in force was to be excluded for the purpose of the 90-day time limit set out in rule 34(5) of the Income-tax (Appellate Tribunal) Rules, 1963 (AY.2011-12).