https://www.taxtmi.com/caselaws?id=118473 Interest on common borrowings used partly for share investment was held disallowable to the extent it related to exempt dividend income under section 14A of the Income-tax Act, 1961. The earlier contention that the assessee carried on an indivisible composite business did not override the statutory bar, because expenditure with a proximate connection to income not forming part of total income cannot be deducted against taxable income. The plea that the shares were acquired for controlling interest was rejected for lack of factual foundation at the appellate stage. The fact that tax may have been paid in the payer company's hands was also irrelevant, since section 14A turns on the tax character of income in the recipient's hands. en-us Tue, 28 Feb 2006 00:00:00 +0530 Sat, 30 Jun 2012 18:20:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=118473 Interest on common borrowings used partly for share investment was held disallowable to the extent it related to exempt dividend income under section 14A of the Income-tax Act, 1961. The earlier contention that the assessee carried on an indivisible composite business did not override the statutory bar, because expenditure with a proximate connection to income not forming part of total income cannot be deducted against taxable income. The plea that the shares were acquired for controlling interest was rejected for lack of factual foundation at the appellate stage. The fact that tax may have been paid in the payer company's hands was also irrelevant, since section 14A turns on the tax character of income in the recipient's hands. Case-Laws Income Tax Tue, 28 Feb 2006 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=118473