2014 (5) TMI 310

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....provisions of Section 14A of the IT Act read with Rule 8D of the IT Rules, to Rs.1,82,374/-. 2. The facts are that the assessee company was engaged in the business of transportation of goods through its own/hired trucks and by rail. In the assessment order, the Assessing Officer disallowed u/s 14A of Rs.24,74,706/- as expenses pertaining to earning of exempt income. During the year, the assessee showed investment in shares and securities of Rs.11,92,91,986/-, which included investment of Rs.60,30,414/- made in shares and mutual funds in earlier years, and investment of Rs.11,31,78,272/- made in the shares of Transrail Logistics Ltd. by transferring a division of the assessee's business and creating a subsidiary company in the said name....

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....und units, amounting to Rs.60,30,414/, and new investments received during the year, i.e., unquoted equity shares and optionally convertible preference shares, amounting to Rs.11,31,78,272/-, total amounting to Rs.11,92,91,986/-. The old investments were acquired from the assessee's own funds in the earlier years. During the year, the company decided to sell its loss making container train business and transferred all its assets and borrowed funds utilized to acquire the said business. A 100% subsidiary company, i.e., M/s Transrail Logistics Ltd. was incorporated for this purpose. The licence obtained from the Ministry of Railways was transferred to Transrail Logistics Ltd. along with all assets and liabilities pertaining to the loss ma....