ACIT CIR-1 , DHANBAD vs. M/S BHARAT COKING COAL LTD, DHANBAD

In the result, appeal of the revenue is dismissed and appeal by the assessee is partly allowed as well as cross-objection by the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

32(2) as amended by Finance Act, 2001 and were available for carry forward and set off against the profits and gains of subsequent years without any limit whatsoever.” 8. In the light of the judicial precedents on the issue especially that of the Hon’ble Gujarat High court in the case of General Motors India Pvt. Ltd. (supra

M/S BHARAT COOKING COAL LTD ,DHANBAD vs. ACIT CIR-1 , DHANBAD

32,000/- under Rule\n8D(2)(iii) of the Rules.\n8. Ld. CIT(A) in the appellate proceedings recorded the finding that\nassessee's own interest free funds were sufficient to cover\ninvestment made in the securities. Ld. CIT(A) noted that the equity\nfund of the assessee was Rs. 4,657 Cr whereas average\ninvestments were only

ACIT CIRCLE-1 , DHANBAD vs. M/S BHARAT COOKING COAL LTD , DHANBAD

32,000/- under Rule\n8D(2)(iii) of the Rules.\n8. Ld. CIT(A) in the appellate proceedings recorded the finding that\nassessee's own interest free funds were sufficient to cover\ninvestment made in the securities. Ld. CIT(A) noted that the equity\nfund of the assessee was Rs. 4,657 Cr whereas average\ninvestments were only