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No disallowance U/s. 14A in absence of actual receipt of income which is not includible in total income
Case Law Details
- Case Name
- Pr. CIT, Nagpur. Vs Ballarpur Industries Limited (Bombay High Court- Nagpur Bench)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All High Courts, Bombay High Court
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Advocate Akhilesh Kumar Sah
The expression “does not form part of the total income” in Section 14A envisages that there should be an actual receipt of the income, which is not includible in the total income, during the relevant previous year for the purpose of disallowing any expenditure incurred in relation to the income in question
Sub-section (1) of section 14A of the Income Tax Act, 1961 (for short ‘the Act’) subject to its Proviso, incorporates that for the purposes of computing the total income under the Chapter IV, no deduction shall be allowed in respect of expenditure incurre...
