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2015 (12) TMI 894 - AT - Income TaxDisallowance u/s 14A r.w.r 8D - Held that:- The assessee is a stock trader and not holding any investment in shares and securities then so far as interest expenditure is concerned, the same cannot be attributable or allocable for earning the dividend income which is only an incidental income and not intended income of the activity of the assessee being trading in shares and securities. We find that in a series of decisions, this Tribunal has decided this issue by holding that no disallowance u/s 14A can be made on account of the expenditure incurred for trading in shares & securities merely because the assessee earned the incidental dividend income. The interest expenditure is exclusively incurred for trading activity and, therefore, cannot be said to be an expenditure incurred for composite activity yielding taxable and non taxable income and accordingly, the same cannot be attributed /allocated in respect of dividend income in the hands of the assessee. As regards the other expenses, we find that the Assessing Officer has not pointed out any expenditure debited to the P&L Account which has any proximate nexus with the dividend income. The entire expenditure debited to the P&L account has a direct nexus with the trading activity of the assessee, therefore, the disallowance made by the assessee on its own is proper and just and no further disallowance on account of administrative expenses is justified. In view of the above discussion, we delete the addition made by Assessing Officer u/s 14A. - Decided in favour of assessee.
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