Assessing authority disallowed the entire debenture interest and finance charges asequity shares were purchased by the assessee out of the borrowed money and, therefore, the entire interest on such debentures and the finance charges were required to be disallowed under section 14A of the Act. Section 14A(1) of the Act Held that where no exempt income is earned in the previous year, relevant to the assessment year in issue, provisions of section 14A of the Act, read with rule 8D could not be invoked. This appeal of the Revenue is, accordingly, dismissed. There shall be no order as to costs.