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2014 (7) TMI 1113 - AT - Income TaxDisallowance u/s.14A - Held that:- The disallowance, it may be appreciated, is of the expenditure incurred, and which may not have any direct bearing on the income arising. Further, where and to the extent the A.O. is not in agreement with the assessee’s claims – for which though we do not see any reason in-as-much as the financial position, properly analyzed, should be able to identify the financing of each asset, either directly with reference to a source of funds, or from the common pool of funds, he shall state his reasons. - transgressed the scope of the appeals in-as-much as our purview, as the second appellate authority, is limited to answer the grounds raised before us. This is not so, as, firstly, the identification of interest allowable, or not so, u/s. 57(iii) is necessarily required to identify and quantify the interest subject to the disallowance u/s.14A. The said section is in fact a complete code in itself, widening the scope of apportionment, as explained in the case of Godrej & Boyce Mfg. Co. Ltd. (2010 (8) TMI 77 - BOMBAY HIGH COURT). Reference in this context may also be made to the decision in the case of Kapurchand Shrimal v. CIT [1981 (8) TMI 2 - SUPREME Court] - Decided in favour of assessee.
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