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2011 (12) TMI 16 - HC - Income TaxCommon Expenditure for Exempt and Taxable Income - expression "in relation to" cannot be ascribed a narrow or constricted meaning - Held That:- If we accept submissions of a assessees then sub-section (1) would be read as follows: "For the purposes of computing the total income under this Chapter, no deduction shall be allowed in respect of expenditure incurred by the assessee with the main object of earning income which does not form part of the total income under this Act.”That is certainly not the purport of the said provision. The expression “in relation to” does not have any embedded object. It simply means “in connection with” or “pertaining to”. If the expenditure in question has a relation or connection with or pertains to exempt income, it cannot be allowed as a deduction even if it otherwise qualifies under the other provisions of the said Act. In Walfort (2010 -TMI - 76751 - SUPREME COURT), made it very clear that the permissible deductions enumerated in sections 15 to 59 are now to be allowed only with reference to income which is brought under one of the heads of income and is chargeable to tax
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