Held that when the interest free area available the presumption that the investment was made from own funds hence disallowance of interest is not warranted. While computing the book profit only actual expenses incurred is liable to be excluded. (AY. 2014-15)
Nirmal Industrial Control P. Ltd. v. ACIT (2021) 90 ITR 34 (SN) (Mum.)(Trib.)
S. 14A : Disallowance of expenditure-Exempt income-Interest free funds-Presumption that the investment was made from own funds-Disallowance of interest is not warranted-Book profit-Only actual expenses incurred is liable to be excluded. [S. 115JB(2), R. 8D (2)(ii), 8(2)(iii)]