https://www.taxtmi.com/caselaws?id=446520 The ITAT Delhi ruled in favor of the assessee on two key issues. Regarding Section 14A disallowance, the tribunal found that tax authorities failed to consider the assessee's suo-moto disallowances and that fresh investments were made from own funds raised through equity issuance, not borrowed funds. The matter was remanded to the AO for fresh consideration following SC precedents. On Section 36(1)(vii) deduction for interest-free loans to subsidiaries, the tribunal allowed the deduction, noting the assessee had sufficient surplus funds and raised capital through share issuance. Following SC precedent in South Indian Bank Ltd., investments were presumed made from interest-free own funds when such funds exceeded investment amounts. en-us Fri, 30 Jun 2023 00:00:00 +0530 Tue, 05 Dec 2023 14:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446520 The ITAT Delhi ruled in favor of the assessee on two key issues. Regarding Section 14A disallowance, the tribunal found that tax authorities failed to consider the assessee's suo-moto disallowances and that fresh investments were made from own funds raised through equity issuance, not borrowed funds. The matter was remanded to the AO for fresh consideration following SC precedents. On Section 36(1)(vii) deduction for interest-free loans to subsidiaries, the tribunal allowed the deduction, noting the assessee had sufficient surplus funds and raised capital through share issuance. Following SC precedent in South Indian Bank Ltd., investments were presumed made from interest-free own funds when such funds exceeded investment amounts. Case-Laws Income Tax Fri, 30 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446520