DCIT CORPORATE CIRCLE 2, CHENNAI vs. SHRIRAM CONSTRUCTION FINANCE, CHENNAI
In the result, the appeal filed by the assessee is allowed and the appeal filed by the Revenue is dismissed
ITA 343/CHNY/2019[2013-14]Status: DisposedITAT Chennai13 Apr 2022AY 2013-14
Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.317/Chny/2019 िनधा"रण वष"/Assessment Year: 2013-14 M/S. Shriram Construction Finance, Vs. The Assistant Commissioner Of Mookambika Complex, No. 4, Income Tax, Lady Desika Road, Mylapore, Non Corporate Circle 2, Chennai 600 004. Chennai. [Pan:Aaafs2597N] आयकर अपील सं./I.T.A. No.343/Chny/2019 िनधा"रण वष"/Assessment Year: 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Construction Income Tax, Finance, Mookambika Complex, Non Corporate Circle 2(1), No. 4, Lady Desika Road, Chennai. Mylapore, Chennai 600 004. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 30.03.2022 घोषणा की तारीख /Date Of Pronouncement : 13.04.2022 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee & The Revenue Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 2, Chennai Dated 26.11.2018 Relevant To The Assessment Year 2013-14. The Grounds Raised By The Assessee Are Reproduced As 2
For Appellant: Shri R. Sivaraman, AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT
Section 143(1)Section 143(2)Section 143(3)Section 147Section 14ASection 36Section 36(1)(iii)
2)(ii) & (iii) made while completing the assessment u/s 143(3) is improper since the same has allowed excessive cost of interest including portion that relates to investments. Since the arithmetic of own money used for investments is not established, it construes that the invested funds have direct nexus to the borrowed fund."
In view of the above, there
