S. 14A : Disallowance of expenditure-Exempt income-Provision is not applicable in case of insurance business which is governed by specific provisions of section 44 and Schedule. I-Foreign tax credit-Foreign tax credit in respect of taxes paid abroad could never exceed Indian tax liability in respect of related income taxed abroad as also in India-Right of respondent under Rule 27 of the ITAT Rules 1963-Appellant cannot be worse off visa-a-vis the position when he was when the appeal was presented. [S. 44, 90, R. 8D, ITAT Rule 27]