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Showing contexts for: proximate cause in Dcit Cc 2, Mumbai vs Aishwarya Rai Bachchan, Mumbai on 18 January, 2017Matching Fragments
"For attracting Section 14A, there has to be a proximate cause for disallowance, which is its relationship with the tax exempt income. Pay-back or return of investment is not such proximate cause, hence, Section 14A is not applicable in the present case. Thus, in the absence of such proximate cause for disallowance, Section 14A cannot be invoked."
v. CIT Vs. Gujarat Power Corporation (Gujarat HC)- The assessee had demonstrated that a majority of the investment in tax-free security were made before the borrowing. The Assessee had other sources of investment and that no part of the borrowed fund could be stated to have been diverted to earn tax free income. As borrowed funds were not used for earning tax-free income, applying s. 14A was not justified.