Assessee claimed deduction on interest paid on borrowed capitals for investing in shares of his two companies.  Assessing Officer disallowed interest, by holding that purpose of investment was to earn income in form of dividend from two companies and same being not taxable, therefore, deductions were not permissible for expenses related to income not forming part of total income under Act. CIT(A) and Tribunal affirmed the disallowance. On appeal the Tribunal held that   since dividend income from two companies was not taxable, in that scenario expenditure incurred on interest paid on funds borrowed in respect of investment in shares of two operating companies was hit by section 14A inasmuch as dividend received on such shares did not form part of total income. Therefore, interest paid on borrowings is  not allowable as deduction.  Followed  Maxopp Investment Ltd v. CIT (2018) 254 Taxman 325 / 402 ITR 640 (SC).   (AY. 1998-99)