Cash inflow treated as income, lenders proved genuine; disallowance of interest expense & investment income rightly deleted.
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....Unsecured loans received by assessee were supported by documentary evidence proving identity, genuineness, and creditworthiness of lenders. No contrary material brought by Revenue to doubt transactions. Hence, no addition u/s 68 was warranted and corresponding disallowance of interest u/s 69C was rightly deleted. Assessee did not earn any exempt income, only gains from investments. Section 14A disallowance applies when exempt income is received/receivable. As no exempt income was earned, disallowance u/s 14A read with Rule 8D was correctly deleted by CIT(A), even considering prospective amendment. Order in favor of assessee upheld.....
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