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2012 (10) TMI 1054 - ITAT MUMBAIDisallowance of interest u/s 14A - legal validity of addition made in the assessment under section 153A - Held that:- time period for issue of notice had expired before date of search - Addition can be made only on the basis of incriminating material found in the course of search - here the disallowance of interest was not based on seized material and therefore no assessment under section 153(3) - Decided in favor of assessee Held that:- AO did have jurisdiction and disallowance had to be considered on merit - Tribunal held that the borrowed funds could not be held to be utilized wholly and exclusively for the purpose of business as same were invested in the company with which the assessee had no business - disallowance of interest is confirmed - Decided against the assessee
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