2013 (6) TMI 718

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....e case are that the assessee contended before the ld. CIT(A) that there was no search and seizure in the case of the assessee company. No panchnama was issued in the name of the company nor the name was mentioned in the panchnama issued in the name of other person. Therefore order passed u/s 153A/143(3) should be annulled. 4. The ld. CIT(A) called for a report from the AO. The AO in his letter dated 01.09.2011 submitted that the panchnama dated 24.04.2009 shows that search and seizure was carried out in the case of the assessee on 24.04.2009 and hence the submission of the assessee that no search and seizure action was carried out u/s 132 of the Act was factually not correct. Therefore the ld. CIT(A) dismissed this ground of appeal of the ....

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....tion for proportionate interest expenditure u/s 24(b) of the Act of Rs. 27,82,018/- out of the total interest expenditure of Rs. 40,67,163/- and disallowed the balance amount of interest expenditure of Rs. 12,84,144/-. 8.1. Before the ld. CIT(A) the assessee submitted that it has made investment in FD as per its balance sheet as on 31.03.2008 of Rs. 34,71,362/- and therefore it is entitled for deduction of interest expenditure for investment in such FDR. 8.2. Thus the ld. CIT(A) observed that the investment of Rs. 26,26,319/- was made at the fag end of the year and only investment of Rs. 8,45,313/- was made under FDR throughout the year. He therefore estimated interest expenditure of Rs. 50,000/- on investment in FDR and allowed deduction....