No Sec. 14A disallowance for shares held as stock in trade

1. Grounds of appeal raised by the revenue reads as follows :- “1. That on the facts and circumstances of the case, the CIT(A) erred as on facts as well as in law in holding that dis allowance u/s 14A of Rs. 43,24,843/- was not warranted as dividend income accrued only from shares kept as stock in trade not from shares kept as investment, ignoring the decision of ITO Vs Cheminvest Ltd as well as CBDT circular No- 5/2014 in this regard which provides that dis allowance u/s 14A read with Rule 8D can be invoked even when shares did not yield exempt income in a particular financial year.”...