https://www.taxtmi.com/caselaws?id=771214 ITAT Delhi allowed the assessee's appeals on three grounds. Section 14A disallowance was deleted as no exempt income was derived during the year. Interest disallowance under Section 36(1)(iii) was removed since the assessee had sufficient interest-free funds (Rs 165.48 crores) exceeding loans to subsidiaries (Rs 102.40 crores), establishing that advances were made from own funds rather than borrowed funds. Penalty under Section 270A was deleted due to defective show-cause notice where AO failed to strike off irrelevant portions, constituting non-application of mind per Bombay HC precedent. en-us Fri, 09 May 2025 00:00:00 +0530 Wed, 21 May 2025 15:31:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771214 ITAT Delhi allowed the assessee's appeals on three grounds. Section 14A disallowance was deleted as no exempt income was derived during the year. Interest disallowance under Section 36(1)(iii) was removed since the assessee had sufficient interest-free funds (Rs 165.48 crores) exceeding loans to subsidiaries (Rs 102.40 crores), establishing that advances were made from own funds rather than borrowed funds. Penalty under Section 270A was deleted due to defective show-cause notice where AO failed to strike off irrelevant portions, constituting non-application of mind per Bombay HC precedent. Case-Laws Income Tax Fri, 09 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771214