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2014 (5) TMI 1228 - ITAT DELHIAddition u/s 14A r.w.r. 8D - claim of the assessee was that no expenditure had been incurred by it to earn the exempt income - HELD THAT:- Undoubtedly, the assessee had not accounted for any expense. AO applied the provisions of Section 14A r.w.r. 8D of the Rules. The issue is as to whether these provisions are applicable to an assessee, who has been admitted to be a dealer in shares, as has been done by the AO in the present case. In ‘CCI Ltd.’ [2012 (4) TMI 282 - KARNATAKA HIGH COURT] has held that if the assessee is a dealer of the shares and securities, it cannot be said that the purchases of the shares and holding of shares made by it were for the purpose of earning of dividend income; and that hence, the expenditure incurred in acquiring these shares cannot be disallowed u/s 14A - like in the present case, it was the admitted position that the assessee was a dealer in shares and securities. ‘CCI Ltd.’ (supra) was followed by the Ahmedabad Bench of the Tribunal in ‘Hina Nitin Parikh’ [2013 (7) TMI 514 - ITAT AHMEDABAD] - Decided in favour of assessee.
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