https://www.taxtmi.com/highlights?id=61736 Disallowance of expenditure u/s 14A read with rule 8D - proportionate disallowance of interest - common pool of funds - if we apply the ratio laid down in the various decisions as discussed to the facts of the present case, the inescapable conclusion would be, as per the balance-sheet the assessee had sufficient interest free fund available with it to take care of the investment. That being the factual position, presumption would be, the investments have been made out of the interest free funds available with the assessee. Hence, no disallowance under rule 8D(2)(ii) can be made. - AT en-us Tue, 01 Feb 2022 08:31:04 +0530 Tue, 01 Feb 2022 08:31:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=61736 Disallowance of expenditure u/s 14A read with rule 8D - proportionate disallowance of interest - common pool of funds - if we apply the ratio laid down in the various decisions as discussed to the facts of the present case, the inescapable conclusion would be, as per the balance-sheet the assessee had sufficient interest free fund available with it to take care of the investment. That being the factual position, presumption would be, the investments have been made out of the interest free funds available with the assessee. Hence, no disallowance under rule 8D(2)(ii) can be made. - AT Highlights Income Tax Tue, 01 Feb 2022 08:31:04 +0530 https://www.taxtmi.com/highlights?id=61736