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    <title>2026 (5) TMI 716 - ITAT DELHI</title>
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    <description>Section 14A applies only to expenditure incurred in relation to income that does not form part of total income. Because dividend income became taxable from assessment year 2021-22 onwards under the Finance Act, 2020 amendment to section 10(34), the foundational condition for invoking Rule 8D was absent in the relevant year. Even if dividend income had arisen, it was not exempt income for that year. Accordingly, disallowance under section 14A read with Rule 8D was not sustainable and was deleted.</description>
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      <description>Section 14A applies only to expenditure incurred in relation to income that does not form part of total income. Because dividend income became taxable from assessment year 2021-22 onwards under the Finance Act, 2020 amendment to section 10(34), the foundational condition for invoking Rule 8D was absent in the relevant year. Even if dividend income had arisen, it was not exempt income for that year. Accordingly, disallowance under section 14A read with Rule 8D was not sustainable and was deleted.</description>
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