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2014 (1) TMI 1723 - AT - Income TaxSales tax subsidy - Revenue receipt OR capital receipt - Held that:- This issue is covered against the assessee by the decision of the Tribunal in assessee’s own case for ay 2006-07 held the subsidy received by the assessee herein to be capital receipt.- Decided in favour of revenue Disallowance u/s 14A r.w.r 8D - Held that:- No dividend was to be declared in view of the provisions of section 25 of Companies Act, 1956. Therefore it was not possible to receive any exempt income from this investment by the assessee. Once there was no exempt income then Sec 14A could not be invoked. Therefore we find force in the submissions of the Ld. Counsel for the assessee and hold that Sec 14A could not have been invoked to make disallowance - Decided in favour of assessee
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