2025 (2) TMI 1854

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....edia, Sr.DR ORDER PER B.R. BASKARAN, A.M : The assessee has filed this appeal challenging the order dt.13-02-2024 passed by the Ld. Commissioner of Income Tax (Appeals), Pune-11 ["Ld.CIT(A)"] and it relates to AY. 2017-18. The only issue urged in this appeal relates to the disallowance of interest expenditure of Rs. 16,11,468/- claimed by the assessee against interest income declared unde....

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....llowed the same. The Ld.CIT(A) confirmed the said addition and hence, the assessee filed this appeal. 3. The main contention of the Ld.AR was that the investments have been made by the assessee out of the own funds. Inviting our attention to the Balance Sheet of the assessee, the Ld.AR submitted that the assessee has got capital balance of Rs. 13.23 crores. The investments made by the assessee ....

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.... own capital and investment in shares. 5. Having heard the rival submissions, we are of the view that there is merit in the submissions made by the Ld.AR. When the own capital available with the assessee is in far excess of the value of the investments, the presumption is that the assessee has made the investments out of own funds only. For this proposition, we may take support from the decisio....