TMI Blog2016 (3) TMI 1374X X X X Extracts X X X X X X X X Extracts X X X X ..... ance could be made u/s. 14A of the Act. The Hon'ble Delhi High Court in the case of Cheminvest Ltd. v. CIT [ 2015 (9) TMI 238 - DELHI HIGH COURT] has categorically held that section 14A envisages that there should be actual receipt of income which was not includible in the total income during the relevant previous year for the purpose of disallowing any expenditure in relation to the said ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eting the disallowance of ₹ 1,82,31,213/- made by the Assessing Officer (hereinafter referred to as the AO) under section 14A rule 8D of the Income Tax Act in relation to the expenditure incurred for investments made for earning of exempt income. 3. At the outset, the Ld. A.R. of the assessee has stated that the Ld. CIT(A) has deleted the disallowance made by the AO after referring to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... diture for earning of exempt income and where the investments have been made by the assessee in the group concern and the primary objection of the investment is to hold controlling stake in the group concern and not earning of any exempt income out of the investment, in such type of strategic investments, disallowance under section 14A is not warranted. Similar proposition of law has been laid do ..... X X X X Extracts X X X X X X X X Extracts X X X X
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