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The Coinage Act, 2011
Section 194I in The Income Tax Act, 1961 [Entire Act]
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Section 194J in The Income Tax Act, 1961 [Entire Act]
Commissioner Of Imcome Tax-Ltu vs M/S. Holcim (India) Pvt. Ltd on 6 July, 2022
"4.2.3 In consideration of the above facts it is seen that the interest
paid by the appellant during the year is not relatable to investment and it is
17
ITA Nos. 6242/Del/2013 & ors.
apparent that there is no nexus between the borrowed money on which
interest was paid and the investments and the interest payments are squarely
related to the business activities of the appellant company. Moreover, as
mentioned above there is no exempt income. Beside the judgments relied
upon by the appellant the facts of the case are also covered in favour of the
appellant by the decision of the Hon'ble Delhi High Court in CIT v. Holcim
India Pvt. Ltd. [2015] 57 taxmann.com 28 (Delhi) and Cheminvest Ltd-v-
ACIT 378 ITR 33 Delhi wherein it has been held that where the interest free
funds available with the assessee were more than investment made in tax
free securities, no disallowance under section 14A could be made. The AO
has incorrectly made further disallowance on this account in the
computation as per Rule 8D of the Income Tax Rules. The addition is
therefore deleted."