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 by or on behalf of such person or accrues or arises or is deemed to accrue or arises to him in India during such year or accrues or arise to him outside India during such year. Considered in aforesaid context, expression ‘total income’ refe...