1. On the facts of assessee entering into an agreement with theagricultural landlords-cum-growers for growing the foundation and breederseeds as per the terms and conditions and also the scientific specificationsprovided by the assessee, when the assessee bears all the expenditure onland development, irrigation, fertilizers, pesticides, transportation etc., whenthe assessee pays the land rent and also for the labour, when the landlordacts only as a grower and hands over the entire agricultural produce offoundation and breeder seeds to the assessee at the end. Grower never soldthe agricultural produce to the assessee etc. Thus, the activity constitutesagricultural activity as the assessee constitutes an agriculturist and theentire activity of production and growing of said seeds becomes anagricultural activity. The solitary evidence gathered by the AO in the solitarycase of Shri Bhuma Bala Narasimha Reddy does not hold good consideringthe fact that the said evidences was not put to the assessee in a settledperspective of legal proceedings. Therefore, procurement of seeds from thelandlords-cum-growers is not the transaction of purchase of seeds for tradingactivity. Further, the judgment of Coordinate Bench of the Tribunal in thecase of Ajeet Seeds Ltd. (supra) was confirmed by the Hon’ble Court ofjudicature Bombay, Aurangabad Bench in the saidcase. Therefore, we are ofthe opinion that the claim made by the assessee is proper. The decision ofCIT(A) is fair and reasonable and does not call for any interference. Therelevant grounds raised by the Revenue are dismissed. 2.AO made disallowance u/s.14A of the Act, as per the discussion given in common ParaNo.5 o f the assessment orders for the A.Yrs. 2013-14 and 2014-15 amounting to Rs. 7,71,422/- and Rs. 13,65,554/- respectively. heinvestment made by the assessee in its subsidiary was not to be reckoned fordisallowance u/s I4A r.w. rule 8D. In thecaseof CIT Vs. RPG TransmissionsLtd (48 taxmann.com 57) , the Madras High Court has held that Interest onborrowed funds utilized for investment in group companies for strategicbusiness purpose was allowable. In the presentcase, the assessee companyhad made investment in Paithan Mega Food Park Pvt. Ltd., an associatecompany which was logical extension of its business. Following the abovedecisions, I direct the AO to delete the addition of Rs. 7,71,422/- made by him.