Disallowance u/s 14A is to be made despite no tax-free income on investment

Lally Motors India (P.) Ltd. Vs  Principal CIT (ITAT Amritsar)

The brief facts of the case are that the Assessing Officer (AO) during the course of assessment proceedings queried the assessee on the applicability of section 14A in view of investment in shares (in Gautam Iron Mills Pvt. Ltd., at Rs. 3.02 crore, as on 31.03.2012 – the year-end.) The assessee replied by stating that it had not earned any income by way of dividend on the said shares, for section 14A of the Act to apply. Reliance was place

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