TMI Blog2014 (4) TMI 713X X X X Extracts X X X X X X X X Extracts X X X X ..... f law arises for consideration – Decided against Revenue. - GA No. 3581 of 2013, I.T.A.T. No. 220 of 2013 - - - Dated:- 9-4-2014 - Girish Chandra Gupta And Sudip Ahluwalia,JJ. For the Appellant : Mr. P. K. Bhowmick,Advocate For the Respondent : Mr. J. P. Khaitan,Sr. Advocate Mr. P. Jhunjhunwalla, Advocate Mr. C. S. Das, Advocate ORDER The Court : - The Assessing Office ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d in 339 ITR 319 wherein the following view was taken : In the case before us, there is no dispute that part of the income of the assessee from its business is from dividend which is exempt from tax whereas the assessee was unable to produce any material before the authorities below showing the source from which such shares were acquired. Mr. Khaitan strenuously contended before us that for th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the production of documentary evidence that such loaned amount had already been paid back and for the relevant assessment year, no interest is payable by the assessee for acquiring those old shares. In the absence of any such materials placed by the assessee, in our opinion, the authorities below rightly held that proportionate amount should be disallowed having regard to the total income and the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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