Disallowance of interest u/s 14A r.w rule 8D unsustainable as borrowed funds not utilized for making investment

DCIT Vs Indian Farmers Fertiliser Cooperative Limited (ITAT Delhi) ITAT Delhi held that disallow of any interest expenditure u/s 14A r.w. Rule 8D of the Act unsustainable as the interest bearing funds borrowed by the assessee have not been utilized for making the investments. Facts- During the course of assessment proceedings, assessee was asked to give the details of investments, the income from which has been claimed as exempt so as to disallow any interest expenditure u/s 14A r.w. Rule 8D of the Act. It was inter alia submitted that the investments have been made out of the society’s own ...