free
bonds/ securities which yield tax free dividend
and interest to assessee Banks when assessee had
sufficient interest free own funds which were more
than ... free bonds/ securities
which yield tax free dividend and interest to Assessee Banks
in those situations where, interest free own funds available
with the Assessee
assessee has not incurred any interest
expenditure in earning such interest income and its interest free
funds are much more than the investment in FDRs ... where both interest
free funds and interest bearing funds are available, then the
investment has been made out of interest free funds. It was
accordingly
conclude that
where both interest free funds and interest bearing funds are
available and the interest free funds are more than the
investments made ... that the amounts invested in the interest free securities
came out of interest free funds available with the petitioner. In
Uday S. Jagtap
hold that where both the interest free funds and interest bearing
funds are available and the interest free funds are more than the investments made ... presumption is that the investment in tax free securities would have been made out of
interest free funds available with the assessee. Since the interest
Ag-8 Ventures Ltd., Bhopal vs Acit, Central-1, Bhopal on 16 February, 2021
आयकर
funds no disallowance can be attributed qua the interest paid on borrowed funds
for investing the same in interest free funds. In view ... that the
amounts invested in the interest free securities came out of interest free funds available with
the petitioner. In that view of the matter
conclude that where both interest free funds and interest bearing funds are
available and the interest free funds are more than the investments made ... that the amounts invested in the interest
free securities came out of interest free funds available with the petitioner. In
that view of the matter
both
interest-free and overdraft and/or loans taken, then a
presumption would arise that investments would be out of the
interest-free fund generated ... available;
both interest free, overdrafts and loans taken, then a presumption
would arise that investment would be out of interest free funds
generated or available
reserves and other funds without interest bearing from relatives and friends
not related to business, to cover funds given interest free or utilized other
than ... funds
are not sufficient to cover interest free advances, a proportionate
disallowance is warranted. While examining interest free funds available with
assessee and interest free
that the amounts invested in the interest free securities
came out of interest free funds available with the petitioner. In
that view of the matter ... amounts which has been invested in the tax free securities have
come out of interest free funds available with it. This is because
once