2016 (5) TMI 1411

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....epartment by: Shri Manoj Kumar O R D E R PER AMARJIT SINGH, JM: The assessee has filed the appeals against the order dated 28.03.2012 and 04.10.2010 passed by the Commissioner of Income Tax (Appeals)-14, Mumbai [hereinafter referred to as the "CIT(A)"] relevant to the assessment year 2004-05 & 2005-06. These appeals are being taken up together for adjudication being the matter of controve....

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.... the above mentioned assessment year before us. 3. However, the assessee has raised number of issues but the learned representative of the assessee only raised the issue u/s.14A of the Income Tax Act, 1961( in short "the Act") wherein the learned CIT(A) confirmed the disallowance the interest expenditure to the tune of Rs. 8,42,08,035/- for A.Y.2004-05 and Rs. 9,70,012/- for A.Y.2005-06. The le....

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....d learned departmental representative has refuted the said contention. In the instant case investment made in subsidiary company for strategic investment i.e. for commercial expediency or investment or stock in trade is in question. Assessing Officer disallowed the interest expenditure to the tune of Rs. 84,20,803/- for A.Y. of 2004-05 and an amount of Rs. 7,70,012/- for the A.Y.2005-06. But in co....