2014 (4) TMI 713

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....itan,Sr. Advocate Mr. P. Jhunjhunwalla, Advocate Mr. C. S. Das, Advocate ORDER The Court : - The Assessing Officer disallowed expenditure for a sum of Rs. 4,03,86,996/- under Section 14A of the Income Tax Act without first recording that he was not satisfied with the correctness of the claim of the assessee in respect of the expenditure in relation to income which is exempt from the liabi....

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....ies below showing the source from which such shares were acquired. Mr. Khaitan strenuously contended before us that for the last few years before the relevant previous years, no new share has been acquired and thus, the loan that was taken and for which the interest is payable by the assessee was not for acquisition of those old shares and, therefore, the authorities below erred in law in giving b....

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....he authorities below rightly held that proportionate amount should be disallowed having regard to the total income and the income from the exempt source. In the absence of any material disclosing the source of acquisition of shares which is within the special knowledge of the assessee, the assessing authority took a most reasonable approach in asssessment." Mr. Khaitan,learned Senior Counsel ap....