2015 (10) TMI 1703

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....reciating that no expenditure was incurred in earning of exempt income. He failed to appreciate that expenditure of Rs. 2 lacs offered by the appellant was reasonable and no further disallowance was called for. 2. That the CIT(A) also erred in making wrong observations that no evidence was produced to the effect that shares were acquired out of own funds and profits of the appellant ignoring the details/documents submitted before him. 3. The appellant company craves leave to alter, amend, vary and/or add any of the grounds of appeal at any time hereinafter." 2. Brief facts of the case are that the appellant company is engaged in the business of manufacturing and trading of grey iron casting, patterns, jigs and fixtures. The assessee had ....

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....iii)] 26,4083   3. Aggrieved by the assessment order, the assessee preferred appeal before the Ld. CIT(A). The Ld. CIT(A) after going through the submissions confirmed the actions of the Ld. A.O. Aggrieved by the Order of Ld. CIT(A), the assessee is in appeal before us now. 4. We have verified the above submissions by both the parties and perused the Statement of accounts submitted by the assessee in paper book. It is seen from the order of the Ld. CIT(A) that the appellant has made investments in the following companies: S.No. Particulars Amount i SRF Equity Shares of Rs. 10 each 503.74 ii  Purearth Infrastructure Ltd. Equity Shares of Rs. 10 each 166.50   These investments have been made in the group companie....

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.....71 lacs during the year under consideration. The secured loans obtained by the company are coming from the earlier years. The majority of interest payments pertains to secured loans and cash credit and over draft facility availed by the appellant. 6. As discussed above the assessee has kept all the funds in a common account and investments and expenditure are made from the same account. No separate account is maintained for the investment purposes which could prove that funds used were not from the interest bearing loans obtained by the appellant. The Ld. CIT(A) has decided the issue on the facts stated above that investment in the shares of SRF Ltd. and Purearth Infrastructure Ltd. was made out of the funds available in common account an....