Section 14A Disallowance Applies Even if Shares Not Acquired for Control; CIT(A) Supports Deletion u/r 8D(2)(ii).

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....Disallowance u/s 14A r.w.r. 8D - though not the dominant purpose of acquiring the shares is a relevant for the purpose of invoking the provisions under section 14 A of the Act, the shares held as stock in trade stand on a different pedestal in relation to the shares that were acquired with an intention to acquire and retain the controlling interest in the investee company - no illegality or irregularity in the Ld. CIT(A) deleting the addition made by the Ld. AO under rule 8D (2) (ii) - AT....