https://www.taxtmi.com/caselaws?id=755572 The Gujarat HC dismissed the Revenue's appeal regarding addition under Section 14A read with Rule 8D(2)(iii) for interest expenses on investments earning exempt income. The assessee had sufficient interest-free funds in share capital and reserves exceeding the exempt income investments. Both CIT(A) and ITAT found no basis for the AO's presumption that borrowed funds were used for such investments. The HC criticized the mechanical grant of sanction by PCIT without proper consideration of case facts and cautioned the Revenue to grant appeal sanctions only in fit cases. en-us Mon, 01 Jul 2024 00:00:00 +0530 Sat, 13 Jul 2024 18:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755572 The Gujarat HC dismissed the Revenue's appeal regarding addition under Section 14A read with Rule 8D(2)(iii) for interest expenses on investments earning exempt income. The assessee had sufficient interest-free funds in share capital and reserves exceeding the exempt income investments. Both CIT(A) and ITAT found no basis for the AO's presumption that borrowed funds were used for such investments. The HC criticized the mechanical grant of sanction by PCIT without proper consideration of case facts and cautioned the Revenue to grant appeal sanctions only in fit cases. Case-Laws Income Tax Mon, 01 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755572