Tribunal Rules Section 14A Cannot Disallow Expenses on Dividend Income Without Challenging Taxpayer's Uncharged Investment Management Claim.

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....Disallowance u/s 14 A - determine the expenditure attributable to earning dividend income - once the Revenue Authorities have found no reason to doubt the Assessee’s claim that the investments have been managed by a group company without levy of charge, it may not be open for the tribunal to disallow expenditure on the basis that some deployment of manpower for managing the investment cannot be “ruled out” - HC....