Interest Disallowance u/s 14A: Assessing Officer Must Prove Interest Not Directly Attributable to Specific Income.

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....Disallowance u/s 14A - rule 8D(2)(ii) clearly is worded in the negative with the words “not directly attributable”. Thus for bringing any interest expenditure, claimed by the assessee, under the ambit of rule 8D(2)(ii) it will have to be shown by the AO that the said interest is not directly attributable to any particular income or receipt - AT....