No disallowance U/s. 14A in absence of actual receipt of income which is not includible in total income

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...