2025 (9) TMI 1443

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....he following grounds of appeal: 1. The Learned Assessing Officer erred in making an addition of Rs. 1,15,40,253/- u/s 14A of the Act r.w.r 8D of the Income Tax Rules, 1962. 2. The Honourable CIT Appeal erred in dismissing the Appeal of Your Appellant on the ground of Non pursuance of the Appeal when the detailed submissions along with eight Judicial Pronouncements were already on the records which were also submitted on the online portal. 3. The Learned CIT Appeal erred in mechanically passing the order without considering the facts of the case as well as legal arguments raised by Your Appellant during the course of Assessment as well as the Appellate Proceedings. 4. Your Appellant pleads Your Honor to de....

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.... funds of Rs. 4.30 crores plus borrowing of Rs. 76 crores. Out of the total borrowing of Rs. 76 crores and 70 crores is raised by issue of non-interest bearing securities viz. optionally convertible Debentures. The short term borrowing (interest bearing) of Rs. 6 crores is used primarily to sustain the business operations. Considering this the question of disallowance interest/business expenditure if not at all arising as dividend bearing investment is out of non-interest bearing securities namely optionally convertible Debentures. The assessee at the time of assessment order has also given the cash flow along with the audited balance sheet. Thus, the assessee submitted before the Assessing Officer that during the year there was no exempt i....