https://www.taxtmi.com/caselaws?id=428939 Section 14A does not apply to expenditure linked to dividend income from an overseas company where that income is included in total income under the Act, even if tax sparing credit or treaty relief is later available under the India-Oman DTAA. The Delhi High Court reasoned that Section 14A is confined to expenditure relating to income that does not form part of total income, and income that remains chargeable in the computation cannot be treated as exempt merely because relief is granted at a later stage under Section 90(2) and Article 25. The disallowance was therefore not attracted, and the Revenue's challenge failed. en-us Tue, 11 Oct 2022 00:00:00 +0530 Sat, 18 Apr 2026 11:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=428939 Section 14A does not apply to expenditure linked to dividend income from an overseas company where that income is included in total income under the Act, even if tax sparing credit or treaty relief is later available under the India-Oman DTAA. The Delhi High Court reasoned that Section 14A is confined to expenditure relating to income that does not form part of total income, and income that remains chargeable in the computation cannot be treated as exempt merely because relief is granted at a later stage under Section 90(2) and Article 25. The disallowance was therefore not attracted, and the Revenue's challenge failed. Case-Laws Income Tax Tue, 11 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=428939