14A

 

IT : Where total income of a dealer of shares includes dividend (which is tax-free income under section 10) from unsold stock of shares (which were retained not with intent to earn dividend income but to trade in them), section 14A not to be invoked to apportion expenditure incurred in purchasing shares between dividend (tax-free income) and share trading profit (taxable income) and disallow expenditure proportionate to dividend income; this is in view of fact that dividend income is only incidental to assessee's business of sale of shares

[2012] 20 taxmann.com 196 (Karnataka)
HIGH COURT OF KARNATAKA

CCI Ltd.

v.

Joint Commissioner of Income-tax