Disallowance u/s 14A while computing book profit u/s 115JB permitted, covered in explanation to Sec.115JB (2)

Brief of the Case ITAT Mumbai held In the case of DCIT vs. Viraj Profiles Ltd. that section 14A provides that it mandates disallowance of expenditure ‘in relation’ to the income which does not form part of the total income while clause (f) in explanation1 to Section 115JB (2) mandates disallowance of expenditure ‘relatable’ to the income to which Section 10 (other than Section 10(38)) or Section 11 or Section 12 applies. The close perusal of the both the above provisions reveals that more or less similar language is used in both the afore-stated provisions. Further the dividend income ...