Held that on a plain textual reading of S. 14A, it is found that the provision mandates that no deduction would be allowed in respect of expenditure that may be incurred for the purposes of earning income which would ultimately not form part of total income under the Act. The expenditure which is thus identified is that which may have been expended for the purposes of earning income which is otherwise not liable to be included in total income and is thus viewed as exempt. The expenditure which is spoken of is thus in respect of income which is specified in S. 10 and which stands placed in Chapter III. S. 14A, on the other hand, is placed in Chapter IV and which contains various provisions relating to computation of total income. Both sub-ss. (1) and (2) of s. 14A, use the expression “income which does not form part of the total income” in conjunction with the expenditure that may be incurred by an assessee in relation thereto. The two expressions noted above are coupled together by the phrase “in relation to”.  Explanation in S. 14A came to be inserted by virtue of the 2022 Act, w.e.f. 1st April, 2022 will  apply in relation to the asst. years. 2022-23 and subsequent assessment years. Income of an assessee has both taxable and non-taxable elements, it would be principle of apportionment of expenditure relating to non-taxable income which would have to be identified for purpose of making disallowance under section 14A.