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Gyscoal Alloys Limited,, Ahmedabad vs The Dy. Cit, Circle-2(1)(1),, ... on 28 September, 2018 cites

Commissioner Of Income Tax Ahmedabad Iv vs Torrent Power Ltd....Opponent(S) on 4 February, 2014

2.7. Thus, from the above fund flow statement, which is verifiable from the bank statement of the appellant also that the investments were made in the A. Y. 2011-12 out of the IPO proceeds and during the year under consideration, the investment remained at Rs.6.12 crore were out of the investments made in A. Y. 2011-12 and not the new investments during the year under consideration. Thus, from the aforesaid details and chart, it is apparent that the sources of the investment in the mutual funds were out of the IPO proceeds which was the interest free funds available with the appellant and no interest expenditure has been incurred thereupon. Thus, the question of making any interest disallowance on these investments does not arise. 2.8. The appellant also relied upon the decision of Hon'ble Gujarat High Court in the case of CIT Vs. Torrent Power Ltd. (supra) and CIT Vs. Gujarat Apollo Industries Ltd. (supra) that the AO has established no nexus of diversion of interest bearing funds utilised for making investment which generate exempt income was on the revenue and considering these judgments, no such disallowance is warranted on interest account in the case of appellant, and therefore, the interest disallowance made by the AO is deleted.
Gujarat High Court Cites 13 - Cited by 85 - S G Gokani - Full Document

Dy.Cit.,Circle-4,, Ahmedabad vs Gujarat Apollo Industries Ltd.,, ... on 16 January, 2017

2.7. Thus, from the above fund flow statement, which is verifiable from the bank statement of the appellant also that the investments were made in the A. Y. 2011-12 out of the IPO proceeds and during the year under consideration, the investment remained at Rs.6.12 crore were out of the investments made in A. Y. 2011-12 and not the new investments during the year under consideration. Thus, from the aforesaid details and chart, it is apparent that the sources of the investment in the mutual funds were out of the IPO proceeds which was the interest free funds available with the appellant and no interest expenditure has been incurred thereupon. Thus, the question of making any interest disallowance on these investments does not arise. 2.8. The appellant also relied upon the decision of Hon'ble Gujarat High Court in the case of CIT Vs. Torrent Power Ltd. (supra) and CIT Vs. Gujarat Apollo Industries Ltd. (supra) that the AO has established no nexus of diversion of interest bearing funds utilised for making investment which generate exempt income was on the revenue and considering these judgments, no such disallowance is warranted on interest account in the case of appellant, and therefore, the interest disallowance made by the AO is deleted.
Income Tax Appellate Tribunal - Ahmedabad Cites 1 - Cited by 7 - Full Document
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