PCIT, Central v. Shapoorji Pallonji and Co. Ltd. (2024) 300 Taxman 182 (SC) Editorial : PCIT, Central v. Shapoorji Pallonji and Co. Ltd. (2024) 164 taxman.com 707 (Bom)(HC)

S. 14A : Disallowance of expenditure-Exempt income-Interest free funds-Presumed that investments were made out of interest-free fund-Disallowance cannot be made-Order of High Court is affirmed-SLP of Revenue is dismissed. [R. 8D, Art.136]

Dismissing the SLP of the Revenue the Court held that High Court held that where both interest-free and interest bearing funds were available with assessee, it was to be presumed that investments were made out of interest-free fund and, thus, disallowance made under section 14A was to be deleted.  AY. 2011-12)

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