2019 (1) TMI 41

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....t : Mr. Percy Pardiwalla, Senior Counsel a/w Ms. Vasanti Patel ORDER P.C. 1. The appeals are admitted for consideration on following substantial question of law : "Whether in law and on the facts and circumstances of the case, was the Tribunal justified in holding that strategic investments made by the respondent company in its subsidiary companies are expenditure which are not d....

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....ties. The Assessing Officer was of the opinion that the interest on the funds borrowed for making such investments would not be an allowable expenditure. The Tribunal relied upon and referred to the judgment of Madras High Court in the case of CIT Vs. Spencer & Co. Ltd. 359 ITR 644 and held that the interest on the borrowed capital were investments in shares utilizing borrowed capital for strat....