How many judgments cite CIT v. Reliance Utilities & Power Ltd.?

2,118 judgments on BharatTax cite CIT v. Reliance Utilities & Power Ltd. (313 ITR 340), spanning 2013 to 2026.

Which sections of the Income Tax Act does CIT v. Reliance Utilities & Power Ltd. come up under?

It is most often cited in judgments turning on Section 14A, Section 36(1)(iii), Section 143(3), Section 115JB, Section 8D, Section 10(34).

CIT v. Reliance Utilities & Power Ltd.

313 ITR 340High Court2009#10 most cited

What is CIT v. Reliance Utilities & Power Ltd. authority for?

Where an assessee claims that investments were made out of own funds, interest disallowance under Section 14A read with Rule 8D may not apply if the assessee demonstrates the availability of sufficient interest-free funds to cover such investments.

2,118

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2013 to 2026.

Also referred to as

CIT v. Reliance Utilities and Power Ltd. · Section 14A · Rule 8D · interest free advances · disallowance of interest expenditure · own funds · interest-free funds

Also reported as

178 Taxmann 13513 DTR 237178 Taxmann.com 135284 CTR 414

Sections most often in play

Section 14A Section 36(1)(iii)Section 143(3)Section 115JB Section 8D Section 10(34)Section 143(2)Section 37(1)

Issues it is cited on

interest free advances disallowance of interest expenditure section 36(1)(iii)disallowance under section 14a commercial expediency disallowance u/s 14a section 14a book profits section 115j section 36(1)section 36 section 115jb

Judgments citing CIT v. Reliance Utilities & Power Ltd.

M/S. Mansarover Investment Ltd, New Delhi vs. ITO, New Delhi

In the result this ground of the assessee is allowed for statistical purposes

ITA 6722/DEL/2013[2010-11]Status: DisposedITAT Delhi11 May 2016AY 2010-11

Bench: Shri H.S.Sidhu & Shri J. Sudhakar Reddyay: 2010-11 Ito, Ward 6(2), Room No.185 Vs. Manasarover Investment Ltd. C.R.Bldg. 28, Najafgarh Road New Delhi New Delhi 110 015 & Ay: 2010-11 Manasarover Investment Ltd. Vs. Ito, Ward 6(2) New Delhi New Delhi (Appellant) (Respondent)

For Appellant: Sh.K.Sampath, Adv. &

Section 14ASection 36(1)(iii)

…t. 6. We find that the assessee had made elaborate submissions before the Ld.CIT(A). In our view the Ld.CIT(A) has erred in not applying the propositions laid down by Hon’ble Mumbai High Court in the case of CIT vs Reliance Utilities & Power Ltd. reported in 313 ITR 340 (Mum), to the facts of the case. When there are sufficient interest free funds available with the assessee, the presumption should be that such funds have been given as interest free advances. The assessee has further demonstrated that it has sufficient interest free funds in the form of share capital and reserves and surplus. On these facts and…

Sbi Dfhi Ltd, Mumbai vs. Addl CIT RG 2(1), Mumbai

In the result, the appeal filed by the assessee is allowed

ITA 6367/MUM/2014[2011-12]Status: DisposedITAT Mumbai10 May 2016AY 2011-12

Bench: Shri Sanjay Arora & Shri Pawan Singhassessment Year: 2011-12 Sbi Dfhi Limited, Addl. Cit, Range 2(1), 23, 3Rd Floor, Voltas House, Aayakar Bhavan, M. K. Road, Churchgate, Mumbai-400020. J.N.Heradia Marg, Bellard Estate, Vs. Mumbai-400001. Pan: Aaacd0532B (Appellant) (Respondent)

For Appellant: Shri Bhavin Shah (AR)For Respondent: Shri Abhishek Meshram (DR)

Section 143(3)Section 14A

…rrectly followed the first appellate order in the assessee's own case for A.Y. 2009- 10, which has been accepted by the assessee itself. 6. We have heard the parties and have perused the material on record. In “CIT vs. Reliance Utilities & Power Ltd.”, (2009) 313 ITR 340 (Bom), it has been held that when there is a common pool of funds, there is a presumption that the investment yielding tax free return is made by the assessee out of its own funds. 'Reliance Utilities and Power Ltd.' (supra) was followed by the Tribunal in the assessee's own case for A.Y. 2003-04, in ITA No. 8645/Mum/2010 (assessee's paper book,…

M/S. Lauls Limited, Faridabad vs. ACIT, Faridabad

In the result assessee’s appeal is allowed in part

ITA 811/DEL/2014[2009-10]Status: DisposedITAT Delhi05 May 2016AY 2009-10

Bench: Shri H.S.Sidhu & Shri J. Sudhakar Reddyay: 2009-10 Lauls Ltd. Vs. Acit, Circle Ii C/O M/S Malhotra Khandelwal & Co. Faridabad 42, Neelam Flyover, 1St Floor Faridabad 121 001 Pan: Aaacl 3118 P (Appellant) (Respondent)

For Appellant: Shri P.C. Panwal, C.A. and Sh. Rakesh Khandelwal, C.AFor Respondent: Ms. Rashmita Jha, Sr. D.R

Section 40

…to the tune of Rs.1.86 crores. The advances in question are only Rs.1.64 crores. The assessee has also demonstrated that it has sufficient interest free funds in this case. The Hon’ble Bombay High Court in the case of CIT vs. Reliance Utilities and Power Ltd. 313 ITR 340/221 CTR 435 (Mum) has laid down that if there are interest free funds as well as interest bearing funds and if there are interest free advances given, the presumption should be that interest free funds have been advanced. The decision of Hon’ble Supreme Court in the case of CIT vs. S.A.Builders Ltd. 288 ITR 1 clinches the issue in favour of the a…

M/S. Strides Arcolab Ltd., Navi Mumbai vs. ITO - 10(3)(4), Mumbai

In the result, assessee’s cross objection is partly allowed

ITA 641/MUM/2007[2003-2004]Status: DisposedITAT Mumbai29 Apr 2016AY 2003-2004

Bench: Shri Saktijit Dey & Shri Ashwani Taneja

For Appellant: Shri Nitesh JoshiFor Respondent: Shri N.K. Chand

Section 115JSection 35

…erest bearing and interest free presumption would be investments made in subsidiary were out of interest free funds. For such proposition, he relied upon the decision of the Hon'ble Jurisdictional High Court in CIT v/s Reliance Utilities and Power Ltd. [2009] 331 ITR 340 (Bom.), and HDFC Bank Ltd. v/s DCIT, W.P. no.1753 of 2016. Further, learned Authorised Representative 34 Strides Shasun Limited Strides Arcolab Limited submitted, there is enough documentary evidence brought on record to show that the overseas subsidiaries are acting as marketing arms of the assessee. He submitted, as a result of investment mad…

M/S Kbd Sugars & Distilleries Ltd, Bangalore vs. Asst. Commissioner of Income-Tax, Bangalore

In the result, the appeal of assessee is partly allowed and the revenue’s appeal is dismissed

ITA 1062/BANG/2014[2011-12]Status: DisposedITAT Bangalore29 Apr 2016AY 2011-12

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri V. Chandrashekar, AdvocateFor Respondent: Shri Sanjay Kumar,CIT-III (D.R)

Section 14A

…]. ITA Nos.1362 & 1363 if 2011 JBD Sugars & Distilleries Ltd., Bangalore. 9.5.2 We shall now analyse the case laws as to whether the AO was within her realm to disallow the interest amount of Rs.10.97 crores. (i) CIT v. Reliance Utilities and Power Ltd (2009) 313 ITR 340 (BOM): (a) In that case, the assessee claimed deduction of interest on borrowed capital. The AO recorded a finding that the sum of Rs.213 crores was invested out of its own funds and Rs.147 crores was invested out of borrowed funds. Accordingly, he disallowed interest of Rs.4.4 crores calculated at 12% per annum. The CIT (A) found that the assess…

D.C.I.T, Circle 3(1), Mumbai vs. Bank of Rajasthan Ltd.(Now Meged With Icici Bank Ltd W.E.F 12.8.2010), Mumbai

The appeal of the Revenue is dismissed

ITA 7094/MUM/2013[2009-10]Status: DisposedITAT Mumbai28 Apr 2016AY 2009-10

Bench: Shri Joginder Singh & Shri Ashwani Tanejaassessment Year: 2009-10 Dcit, M/S Bank Of Rajasthan Ltd. Circle-3(1), (Now Merged With Icici बनाम/ Room No.607, Bank Ltd. On 12.08.2010) Vs. 6Th Floor, Aayakar Bhavan, Icici Bank Tower, 9Th Floor, Mumbai-400020 South East Wing Bandra (E), Mumbai-400051 (राज"व /Revenue ) ("नधा"रती /Assessee) Pan. No.Aaact7434N

Section 10(34)Section 14A

…, the investment was made out of own funds only and not from the borrowed funds. In such a situation, the assessee gets support from the decision in Rajasthan state warehousing corporation vs CIT (242 ITR 450)(SC), CIT vs Reliance Utilities and Power Ltd. (313 ITR 340)(Bom.), CIT vs Hero Cycles 323 ITR 518 (P&H) and various decisions of the Tribunal mentioned at page-5 of the impugned order. It is further noticed that the assessee itself offered an amount of Rs.18,12,188/- being 1/2% of the average value of the investment as per rule 8D(2)(iii) of the rules, therefore, considering the aforementioned decisio…

Rafique A Malik, Mumbai vs. Addl CIT 2(2), Mumbai

In the result, assessee’s appeal is partly allowed

ITA 4820/MUM/2012[2008-09]Status: DisposedITAT Mumbai22 Apr 2016AY 2008-09

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

For Appellant: Shri D.V. LakhaniFor Respondent: Shri B.S. Bist

Section 14ASection 154Section 234B

…t interest free funds available with him to take care of the investment giving rise to 5 Shri Rafique A. Malik exempt income. Thus, in terms with the ratio laid down by the Hon'ble Jurisdictional High Court in CIT v/s Reliance Utilities and Power Ltd. [2009] 331 ITR 340 (Bom.) and CIT v/s HDFC Bank Ltd. [2014] 366 ITR 505 (Bom.), no disallowance out of interest expenditure should be made. As far as indirect / administrative expenditure is concerned, it is observed from the income and expenditure account as on 31st March 2008, the expenditure claimed by the assessee are against specific head of income shown in th…

DCIT, Bangalore vs. M/S Jsr Constructions Private Limited, Bangalore

ITA 875/BANG/2014[2008-09]Status: DisposedITAT Bangalore13 Apr 2016AY 2008-09

Bench: Shri Abraham P. Geoerge & Shri George George K.Assessment Year : 2008-09

For Appellant: Shri V. Chandrashekar, AdvocateFor Respondent: Shri Sunil Kumar Agarwala, Jt. CIT(DR)

Section 144

…,86,988. Thus, as per ld. AR, the loans of Rs.4.45 crores as on 31.3.2007 and Rs.3 crores as on 31.3.2008 were given out of interest free funds. Relying on the judgment of the Hon’ble Bombay High Court in the case of CIT v. Reliance Utilities and Power Ltd., 313 ITR 340, the ld. AR submitted that if interest free funds and interest bearing funds were both available, then a presumption would arise that loans were first given out of interest free funds. Reliance was also placed in the case of M/s. KBD Sugars & Distilleries Ltd. v. ACIT, ITA Nos. 1362 & 1363/Bang/2011 dated 22.11.2013. 10. Per contra, ld. DR stro…

Jsr Constrctions Pvt. Ltd., Bangalore vs. Addl..C.I.T., Bangalore

ITA 741/BANG/2014[2008-09]Status: DisposedITAT Bangalore13 Apr 2016AY 2008-09

Bench: Shri Abraham P. Geoerge & Shri George George K.Assessment Year : 2008-09

For Appellant: Shri V. Chandrashekar, AdvocateFor Respondent: Shri Sunil Kumar Agarwala, Jt. CIT(DR)

Section 144

K . Raheja Corp P. Ltd, Mumbai vs. Asst CIT Cen Cir 29, Mumbai

ITA 6900/MUM/2011[2008-09]Status: DisposedITAT Mumbai04 Apr 2016AY 2008-09

For Appellant: Shri P.J. Pardiwala & Ms. Aarti SatheFor Respondent: Shri Arvind Kumar

Section 14Section 143(3)Section 14ASection 254(1)

…आयकर अपीलीय आयकर अपीलीय अिधकरण अिधकरण," ए” खंडपीठ खंडपीठ मुंबई मुंबई आयकर आयकर अपीलीय अपीलीय अिधकरण अिधकरण खंडपीठ खंडपीठ मुंबई मुंबई INCOME TAX APPELLATE TRIBUNAL,MUMBAI-“A”,BENCH सव"ी जोिग"दर "सह, "याियक सद"य एवं राजे"", लेखा सद"य Before S/ShJoginder Singh,Judicial Member & Rajendra,Accountant Member आयकर अपील सं./ITA No./6900/Mum/2011,िनधा"रण िनधा"रण वष" वष" /Assessment Year: 2008-09 िनधा"रण िनधा"रण वष" वष" M/s. K. Raheja Corporation Pvt. Ltd. ACIT , Central Circle-29 Raheja Tower, Plot No.C-30,G-Block, Opp. Mumbai. Vs. SIDBI, BKC ,Bandra (E),Mumbai-400 051. PAN:AAACP 0522 B (अपीलाथ" /Appellant) (""यथ" / R…

ACIT, New Delhi vs. M/S Gillete Diversified Operations Pvt. Ltd., New Delhi

ITA 499/DEL/2013[2005-06]Status: DisposedITAT Delhi01 Apr 2016AY 2005-06

Bench: Shri I.C.Sudhir & Shri Prashant Maharishiacit, Gillete Diversified Operations Pvt. Ltd., Circle-12(1), C/O. Jaikumar Tejwani & Co, Ca, Vs. New Delhi B-50, East Of Kailash, New Delhi Pan:Aaacg2469C (Appellant) (Respondent) Gillete Diversified Operations Pvt. Ltd., Acit, C/O. Jaikumar Tejwani & Co, Ca, Circle-12(1), Vs. B-50, East Of Kailash, New Delhi New Delhi Pan:Aaacg2469C (Appellant) (Respondent)

For Appellant: Sh. Pradeep Dinodia, AdvFor Respondent: Sh.Subhakant Sahu, Sr. DR

Section 14A

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I-2”: NEW DELHI BEFORE SHRI I.C.SUDHIR, JUDICIAL MEMBER AND SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER ACIT, Gillete Diversified Operations Pvt. Ltd., Circle-12(1), C/o. Jaikumar Tejwani & Co, CA, Vs. New Delhi B-50, East of Kailash, New Delhi PAN:AAACG2469C (Appellant) (Respondent) Gillete Diversified Operations Pvt. Ltd., ACIT, C/o. Jaikumar Tejwani & Co, CA, Circle-12(1), Vs. B-50, East of Kailash, New Delhi New Delhi PAN:AAACG2469C (Appellant) (Respondent) Revenue by : Sh.Subhakant Sahu, Sr. DR Assessee by: Sh. Pradeep Dinodia, Adv Sh. R. K. Kapoor, CA Date of Heari…

DCIT - 1(3), Mumbai vs. M/S Stci Ltd. (Formerly Known As Securities Trading Corp. of India Ltd.), Mumbai

In the result, Department’s appeals are allowed for statistical purposes

ITA 2580/MUM/2013[2008-09]Status: DisposedITAT Mumbai31 Mar 2016AY 2008-09

Bench: Shri Saktijit Dey & Shri Ramit Kochar

For Appellant: Shri Bhavin Shah a/wFor Respondent: Shri Ritesh Misra

Section 14A

…cumstances, no disallowance should have been made by the Assessing Officer under section 14A r/w rule 8D. In support of his contentions, learned Authorised Representative relied upon the following decisions:– i) CIT v/s Reliance Utilities & Power Ltd. [2009] 313 ITR 340 (Bom.); ii) CIT v/s HDFC Bank Ltd., W.P. no.1753/2016, judgment dated 25th February 2016; and iii) CIT v/s HDFC Bank Ltd., [2014] 366 ITR 505 (Bom.). 14. Learned Departmental Representative, however, pointed out that the assessee itself has made the disallowance of ` 1,53,10,783, in the computation of income filed along with the return of income…

Smt. Sudesh Yadav, Mahendergarh vs. ITO, Narnaul

The appeal is allowed

ITA 514/DEL/2013[2009-10]Status: DisposedITAT Delhi31 Mar 2016AY 2009-10

Bench: Shri I.C. Sudhir & Shri O.P. Kant Assessment Year: 2009-10 Sudesh Yadav, Vs. Ito, W/O Vijay Paul Rao, Ward-2, Prop. M/S. Mahaluxmi Petroleum, Narnaul. Narnaul Road, Mohendergarh. (Pan: Abrpy5153A) (Appellant) (Respondent) Assessee By: Shri P.C. Yadav & Ms. Shubhangni Yadav, Adv. Department By: Shri Anima Barnwal, Sr. Dr Date Of Hearing : 17 .03.2016 Date Of Pronouncement: 31:03.2016 Order Per I.C. Sudhir:The Assessee Has Questioned First Appellate Order Mainly On The Grounds That The Learned Cit(Appeals) Has Erred In Sustaining The Disallowances Of: I) The Claimed Depreciation At Rs.4,56,960 On A New Tank Lorry Purchased For Rs.15,23,110; & Ii) Interest Of Rs.40,400 In Respect Of Old Advance Made To Dr. Rajbir Singh Out Of Self Capital. 2. Besides, An Application Has Been Moved By The Assessee Under Rule 11 Of The Appellate Tribunal Rules, 1963 For Allowing The Following Additional

For Appellant: Shri P.C. Yadav & Ms. ShubhangniFor Respondent: Shri Anima Barnwal, Sr. DR

Section 2(11)Section 32(1)(iii)

…No. 37 of the paper book showing that there was unsecured loan to the tune of Rs.35,93,184 and paid up capital of the proprietor at Rs. 10,40,961. He placed reliance on the following decisions: 7 i) Bharti Tele-venture 331 502 (Del.); ii) Reliance Utility – 313 ITR 340 (Bom.) 11. The Learned Senior DR on the other hand placed reliance on the orders of the authorities below with this further submission that the assessee has failed to establish that the advance was given to Dr. Rajbir Singh for the purpose of business. 12. Considering the above submissions, we find that while making the disallowance the Assessing…

The Commissioner of Income- Tax - V vs. M/s. Krishnaveni Constructions

ITTA/37/2010HC Telangana22 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Kiran Gems P.Ltd, Mumbai vs. Addl CIT 5(2), Mumbai

The appeal of the assessee is allowed

ITA 7403/MUM/2012[2008-09]Status: DisposedITAT Mumbai14 Mar 2016AY 2008-09

Bench: Shri Joginder Singh & Shri Rajendraassessment Year-2008-09 M/S Kiran Gems Private Ltd. Addl.Cit-5(2), Fe 5011, Bharat Diamond Aayakar Bhavan, बनाम/ Bourse, G-Block, M.K. Road, Vs. Bandra Kurla Complex, Mumbai-400020 Bandra (East), Mumbai-400051 Pan No.Aadck1665M (राज"व /Revenue) ("नधा"रती /Assessee)

Section 143(2)Section 36(1)(iii)

…आयकर अपील"य अ"धकरण, मुंबई "यायपी “ए”,मुंबई । IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES “A”, MUMBAI "ी जोिग"दर "सह, "याियक सद"य एवं "ी राजे"", लेखा सद"य, के सम" । Before Shri Joginder Singh, Judicial Member and Shri Rajendra, Accountant Member Assessment Year-2008-09 M/s Kiran Gems Private Ltd. Addl.CIT-5(2), FE 5011, Bharat Diamond Aayakar Bhavan, बनाम/ Bourse, G-Block, M.K. Road, Vs. Bandra Kurla Complex, Mumbai-400020 Bandra (East), Mumbai-400051 PAN No.AADCK1665M (राज"व /Revenue) ("नधा"रती /Assessee) "नधा"रती क" ओर से / Assessee by Shri K.A. Vaidyalingam Shri M. Murli-DR राज"व क" ओर से / Revenue by…

Swetal N. Desai, Mumbai vs. ITO 8(3)(2), Mumbai

In the result, appeal stands partly allowed

ITA 7322/MUM/2012[2009-10]Status: DisposedITAT Mumbai11 Mar 2016AY 2009-10

Bench: Shri Saktijit Dey & Shri Ramit Kochar

For Appellant: Shri Mehul ShahFor Respondent: Shri Ritesh Misra

…e funds available. He, therefore, submitted, in such circumstances, no disallowance of interest expenditure can be made. For such proposition, he relied upon the decision of Hon'ble Jurisdictional High Court in CIT v/s Reliance Utilities and Power Ltd. [2009] 313 ITR 340 (Bom.). Further, learned Authorised Representative submitted, the Assessing Officer has not established nexus between the borrowed funds and so called interest free advance. Alternatively, it was submitted as the assessee has obtained the borrowed fund at the interest rate of 14.25%, whereas it has advanced loan by charging interest @ 12% the exc…

ACIT, New Delhi vs. M/S Dlf Ltd., New Delhi

ITA 3061/DEL/2011[2006-07]Status: DisposedITAT Delhi11 Mar 2016AY 2006-07

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

Section 133ASection 142Section 143(2)Section 144Section 146Section 250

…lied on the decisions of honorable Supreme Court in ACIT v. Tulip Star Hotels Ltd. (Supreme Court) (CC 7138-7140/2012) and honorable Bombay high court in CIT v. HDFC Bank Ltd. (2014) 107 DTR (Bom) 140 and CIT Vs. Reliance Utilities & Power Ltd. 178 Taxman 135/313 ITR 340/221 CTR (Bom.) 435 etc. (v) The next argument advanced was that profit from the firm in the hands of the assesse partner is doubly taxed income and is not exempt income. For this, he relied on the Circular No.636-dated 31.08.1992 wherein CBDT has held that the profits from the firm are doubly taxed income. Therefore, it was his contention that pr…

Dlf Ltd., New Delhi vs. Addl. CIT, New Delhi

ITA 2677/DEL/2011[2006-07]Status: DisposedITAT Delhi11 Mar 2016AY 2006-07

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

Section 133ASection 142Section 143(2)Section 144Section 146Section 250

The Commissioner of Income Tax vs. M/S Microlabs Ltd

The appeal is dismissed

ITA/471/2015HC Karnataka11 Mar 2016

Bench: B.V.NAGARATHNA,JAYANT PATEL

Section 14ASection 154Section 260Section 35

…t that the availability of profit, share capital and reserves & surplus was much more than investments made by the assessee which could yield tax free income. - 14 - 41. The Hon’ble Bombay High Court in Reliance Utilities & Power Ltd. 313 ITR 340 (Bom) has held that where the interest free funds far exceed the value of investments, it should be considered that investments have been made out of interest free funds and no disallowance u/s. 14A towards any interest expenditure can be made. This view was again confirmed by the Hon’ble Bombay High Court in CIT v. HDFC Bank Ltd., ITA N…

DCIT 8(1), Mumbai vs. Enercon India Ltd, Mumbai

In the result, both the appeals of the revenue are dismissed

ITA 4089/MUM/2012[2008-09]Status: DisposedITAT Mumbai08 Mar 2016AY 2008-09

Bench: Shri C.N. Prasad, Jm & Shri Rajesh Kumar, Am आमकय अऩीर सं./I.T.A. No.6751/Mum/2011 (ननधधायण वषा / Assessment Years: 2007-08) Dy. Commissioner Of Income Tax M/S Enercon India Limited, –Range 8(1), Enercon Tower, A-9, Room No.210, Veera Industrial Estate, फनधभ/ Aayakar Bhavan, Veera Desai Road, Vs. M.K.Road, Andheri (W), Mumbai-400020 Mumbai-400053

For Appellant: Shri Manjunatha SwamyFor Respondent: Shri J P Bairagra

Section 115JSection 143(2)Section 143(3)Section 14ASection 36(1)(iii)Section 43(5)Section 43(5)(a)

…ition made by the AO on account of interest on the ground that the assessee‟s own funds were far more than the investment made in the subsidiaries companies and therefore relying on the decisions in the cases of CIT V/s Reliance Utilities and Power Ltd (2009) 313 ITR 340 (Bom), Woolcombers of India Ltd V/s CIT 1981) 23 CTR (Cal) 204 and East India Pharmaceuticals Works Ltd V/s CIT (1987) 139 CTR (SC) 372 deleted the disallowance made on account of interest while sustaining the disallowance in respect of other in direct expenses at the rate of 0.5% of the average of value of investment which came to Rs.1,35,14,428…