Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
Assessee held shares as stock-in-trade for trading purposes, not to earn dividend income. HC held provisions of Section 14A disallowing expenses relatable to exempt income inapplicable as no exempt income accrued. Where shares held as stock-in-trade, earning dividend immaterial; purpose is to trade by selling when price rises to earn profits. Situation differs from holding shares to retain control over investee company and intentionally earning dividend. Decided against revenue.
Assessee held shares as stock-in-trade for trading purposes, not to earn dividend income. HC held provisions of Section 14A disallowing expenses relatable to exempt income inapplicable as no exempt income accrued. Where shares held as stock-in-trade, earning dividend immaterial; purpose is to trade by selling when price rises to earn profits. Situation differs from holding shares to retain control over investee company and intentionally earning dividend. Decided against revenue.
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