2017 (12) TMI 1560

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....r. Kotangale, the learned counsel for the Revenue urges the following two questions of law for our consideration:- "(a) Whether on the facts and in, the circumstances of the case and in law, the Tribunal was justified in deleting the additions made on account of disallowance of interest of Rs. 43,78,306/- on interest bearing advances to subsidiary companies?" "(b) Whether on the facts and in, the circumstances of the case and in law, the Tribunal was justified in upholding the decision of the CIT (A) on deleting disallowance of Rs. 42,71,943/- under section 14A of the I.T. Act, 1961?" 3. Regarding Question No.1:- (a)  During the course of assessment proceedings the Assessing officer noticed that the Respon....

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....e had invested in its subsidiary companies and being its holding company it had interest in its success. It further records the fact that the Respondent - Assessee was having its own interest free funds to the tune of Rs. 169.14 Crores while the investment made in the subsidiary was to the tune of Rs. 51.47 Crores. Thus the Respondent - Assessee was in possession of surplus interest free funds sufficient to meet its investment in its subsidiary companies. Thus, relying upon the decision of the Apex Court in S.A. Builders Ltd. (supra), dismissed the Revenue's appeal. (d) Mr. Kotangale, the learned counsel for the Revenue urges that its complaint with the impugned order is that it does not record the nature of business interest, ....