https://www.taxtmi.com/caselaws?id=426829 Where an assessee's own interest-free funds exceeded loans and advances to sister concerns, a presumption arose that the outgoings came from those funds, so no proportionate interest disallowance under section 36(1)(iii) was justified. For section 14A, disallowance could not be made in a year with no exempt income; where exempt income existed, the interest limb under Rule 8D(2)(ii) still failed because own funds were sufficient, and only the administrative expenditure limb under Rule 8D(2)(iii) required recomputation with the investment base confined to exempt-income investments. The interest disallowance was deleted, one year's section 14A disallowance was fully deleted, and the other year was remanded only for limited recomputation. en-us Mon, 22 Aug 2022 00:00:00 +0530 Fri, 26 Aug 2022 13:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=426829 Where an assessee's own interest-free funds exceeded loans and advances to sister concerns, a presumption arose that the outgoings came from those funds, so no proportionate interest disallowance under section 36(1)(iii) was justified. For section 14A, disallowance could not be made in a year with no exempt income; where exempt income existed, the interest limb under Rule 8D(2)(ii) still failed because own funds were sufficient, and only the administrative expenditure limb under Rule 8D(2)(iii) required recomputation with the investment base confined to exempt-income investments. The interest disallowance was deleted, one year's section 14A disallowance was fully deleted, and the other year was remanded only for limited recomputation. Case-Laws Income Tax Mon, 22 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=426829