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    <title>2024 (7) TMI 280 - ITAT AHMEDABAD</title>
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    <description>Section 14A read with Rule 8D requires a demonstrated nexus between expenditure and exempt income, with recorded dissatisfaction before a mechanical disallowance is made; on the facts, the disallowance was confined to exempt dividend income because the assessee showed use of interest-free funds and no direct expense. Allegations that loss on sale of shares was non-genuine could not stand where the assessee produced contract notes, demat statements, broker ledgers and bank records, and the Revenue relied only on suspicion and unverified investigation material. An amount shown as speculation loss was treated as depreciation relatable to the speculation business, as the computation supported the assessee&#039;s treatment and there was no factual basis for a separate addition.</description>
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      <description>Section 14A read with Rule 8D requires a demonstrated nexus between expenditure and exempt income, with recorded dissatisfaction before a mechanical disallowance is made; on the facts, the disallowance was confined to exempt dividend income because the assessee showed use of interest-free funds and no direct expense. Allegations that loss on sale of shares was non-genuine could not stand where the assessee produced contract notes, demat statements, broker ledgers and bank records, and the Revenue relied only on suspicion and unverified investigation material. An amount shown as speculation loss was treated as depreciation relatable to the speculation business, as the computation supported the assessee&#039;s treatment and there was no factual basis for a separate addition.</description>
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