Section 14A apply on investment made for acquiring controlling interest 

Puran Associates Pvt. Ltd. Vs ACIT (ITAT Delhi) The issue under consideration is whether the expense disallowed u/s 14A by A.O. is justified in law? In the present case, the assessee is engaged in the business of sale and purchase of the shares in mutual funds. During the year, the assessee disclosed income of ₹ 3 crores and made disallowance of ₹ 10,82,334/-, under section 14A of the Act. The Assessing Officer, rejected the action of the assessee and disallowed ₹53,16,568/- u/s 14A claiming to be expense on account of the income on which no activity was done in the previous year. The as...