Expense specifically relatable to taxable income cannot be disallowed U/s. 14A & Rule 8D

Once it is found that an expense is specifically relatable to a taxable income, as is the undisputed position in this case, no portion of such an expense can be disallowed u/s. 14A. The allocation of general expenses vis-à-vis tax exempt income and taxable income can only be made in respect of expenditure which cannot either be wholly allocated to taxable income, then or which can not be wholly allocated to tax exempt income; the allocation can be made, even on the basis of formula set out in Rule 6D(iii), in respect of such expenses which do not fall any of these categories. There is no infi...