Section 14A – Investment not resulting in any exempt income cannot be considered for of disallowance under Rule 8D(2)(i)

Definition of ‘total income u/s 2(45) refers to  section 5 which envisages ‘scope of total income’. On a reading of section 5 of the IT Act, it would be evident that as per this section ‘total income’ is of any previous year and which includes income from whatever source derived which is received or deemed to be received in India in such year

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