Dismissing the appeal of the revenue the Court held that The Tribunal had affirmed the order of the CIT(A) deleting the addition made by the Assessing Officer under section 14A on the ground that the interest-free funds available with the assessee were far in excess of the advance given. The principle of apportionment under rule 8D of the Income-tax Rules, 1962 did not arise as the jurisdictional facts had not been pleaded by the Department. That finding of the CIT(A) as affirmed by the Tribunal was that the assessee had not utilised interest bearing borrowed funds for making interest-free advances but had its own interest-free fund far in excess of interest-free advance. ( AY.2010-11)