Own Funds vs Borrowed Funds: ITAT Remands 14A Case for De Novo Review

Srivaru Agro Pvt. Ltd Vs ACIT (ITAT Kolkata) ITAT Kolkata: 14A Disallowance Remanded – Own Funds vs Borrowed Funds to be Verified as per South Indian Bank Ruling Kolkata ITAT dealt with disallowance u/s 14A r.w. Rule 8D of ₹25.71 lakh made by AO. Assessee contended that its own interest-free funds of ₹13.48 crore far exceeded the total investments of ₹11.81 crore & hence no disallowance of interest was warranted as per the Supreme Court ruling in South Indian Bank Ltd. v. CIT (2021) 10 SCC 153. It was further argued that only one investment had yielded dividend income & total a...