No Disallowance of Interest on Loan taken to earn taxable business Income U/s. 14A r.w. Rule 8D(2)(ii)

The issue of revenue’s appeal is that the CIT(A) has wrongly deleted the dis allowance made by AO under Rule 8D(2)(ii) of the Rules at Rs. 55,47,700/-. Here the assessee before the lower authorities and even before us explained that out of the total interest payment of Rs.97,22,656/-, the interest aggregating to Rs. 92,69,529/- was paid to Brila Global Finance Co. Ltd., DSP Merill Lynch Capital Ltd. and J.M. Financial Products Pvt. Ltd. is relating to loans taken for IPOs shares, which were business transaction and taken in stocks. To prove this point the assessee explained that the shares w...