Search Results Page
Search Results
1 - 10 of 37 (0.67 seconds)Section 80JJAA in The Income Tax Act, 1961 [Entire Act]
Section 14A in The Income Tax Act, 1961 [Entire Act]
The Income Tax Act, 1961
The Companies Act, 1956
Section 135 in The Companies Act, 1956 [Entire Act]
Section 144B in The Income Tax Act, 1961 [Entire Act]
Reliance Capital Ltd, Mumbai vs Dcit Rg 3(3), Mumbai on 31 August, 2017
28. The learned CIT(A), after examining the financial statements
of the assessee, recorded a finding that the assessee had own
funds in the form of share capital and reserves amounting to
about Rs. 12,257 crore, whereas the investments in exempt
income yielding securities amounted to about Rs. 3,041 crore. On
these facts, the learned CIT(A) held that the investments were
fully covered by interest-free funds and therefore no disallowance
of interest expenditure was warranted. While arriving at this
conclusion, the learned CIT(A) relied upon the decision of the
Hon'ble Bombay High Court in CIT vs. Reliance Utilities and
Power Ltd. (313 ITR 340).In the present case, the factual finding
recorded by the learned CIT(A) that the assessee possessed
substantial interest-free funds far in excess of the investments
has not been controverted by the Revenue by bringing any
contrary material on record. Once such factual position is
accepted, the presumption laid down by the Hon'ble Bombay
High Court squarely applies and the conclusion drawn by the
learned CIT(A) that no disallowance of interest expenditure was
warranted does not call for any interference.