Case Law Details
Case Name : Dy. Commissioner of Income Tax Vs M/s. Maharashtra Seamless Ltd. (ITAT Delhi)
Related Assessment Year : 2003- 04
Courts :
All ITAT ITAT Delhi
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As the funds were mixed, it is not possible to ascertain whether the investment in tax free bonds is out of the assessee’s own funds. The source of investment in the tax free bonds was not identified. The AO did not establish any nexus between the borrowed funds and the investments in the tax free bonds. The cash flow of the assessee was not seen. Therefore, the apportionment on a pro rata basis was improper in the absence of anything brought by the AO to rebut the assessee’s stand that the investment in the tax free bonds had been made out of the funds of o
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Subsection 3 of Section 40A of Income Tax is applicable to cash paid to daily labour wages