https://www.taxtmi.com/caselaws?id=20866 HC held that deduction under s.80M is admissible only on net dividend income, i.e., gross intercorporate dividend reduced by actual expenditure incurred in earning such dividend. The Court ruled that there is no scope for estimating or allocating notional or proportionate expenses where no factual basis exists and no fresh investments in dividend-yielding shares were made in the relevant years. Only proven, actual expenses can be deducted before computing the s.80M relief. As the assessing officer had made an impermissible notional allocation, HC declined to answer the reference and directed the Tribunal to ascertain actual expenditure and recompute relief accordingly. en-us Mon, 06 Apr 1992 00:00:00 +0530 Wed, 10 Dec 2025 19:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=20866 HC held that deduction under s.80M is admissible only on net dividend income, i.e., gross intercorporate dividend reduced by actual expenditure incurred in earning such dividend. The Court ruled that there is no scope for estimating or allocating notional or proportionate expenses where no factual basis exists and no fresh investments in dividend-yielding shares were made in the relevant years. Only proven, actual expenses can be deducted before computing the s.80M relief. As the assessing officer had made an impermissible notional allocation, HC declined to answer the reference and directed the Tribunal to ascertain actual expenditure and recompute relief accordingly. Case-Laws Income Tax Mon, 06 Apr 1992 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=20866