2016 (2) TMI 910

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....nds of appeal is relating to the confirmation of addition under section 14A of Rs. 2,46,650/-. At the outset, the Ld. A.R. of the assessee has invited our attention to page 11 of the paper book which is the detail of investments to show that 99.98% of the total investments were made in the group companies. The assessee has contended that the same were strategic investments for having control over the group companies. The Ld. A.R. of the assessee has further submitted that the investments so made were old investments and that no new investments were made during the year. He, therefore, has submitted that the strategic investments made by the assessee were not for the purpose of earning of exempt income but the same were relating to the bu....

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....fore, strategic investment should be excluded for attributing administrative expenses for making disallowance u/s 14A of the Act. The ld. A.R. has placed reliance on the following decisions:- i) HSBC Securities and Capital Markets (I) P. Ltd. - ITA No. 3186/M/08 ii) Zenstar Technologies Ltd. - ITA No. 4538/M/05 iii) Shri Bhalchandra R. Sule - ITA No. 3684/M/05 iv) EIH Associated Hotels vs. DCIT - ITA No. 1503/Mad/12 v) Interglobe Enterprises Ltd. vs. DCIT - ITA No. 1362 & 1032/De1/13 vi) JM Financial Limited vs. ACIT - ITA No. 4521/M/12 vii) CIT vs. Oriental Structural Engineers P. Ltd. - ITA 605 of 2012(HC) viii) ACIT vs. Oriental Structural Engineers P. Ltd. ITA No. 4245/De1/2011 ix) Garware Wall Ropes Ltd. vs. ....