PCIT v. Kalpataru Power Transmission Ltd. (2024) 301 Taxman 427 (Guj.)(HC)

S. 14A : Disallowance of expenditure-Exempt income-Own interest free funds-Investment in its subsidiaries-No disallowance of interest expenditure can be made.[R.8D]

The High Court in case of CIT v. Suzlon Energy Ltd. [2013] 33 taxmann.com 151/215 Taxman 272/354 ITR 630 (Guj)(HC)  has held that where the assessee had own interest free funds many times over the investment made in its subsidiaries and further, there was no direct nexus between the interest bearing borrowed funds and such investment, no disallowance of interest expenditure could be made under section 14A. Order of Tribunal is affirmed. (AY. 2015-16)