High Court  held that section 14A envisages that there should be an actual receipt of income which is not includible in total income; hence, section 14A will not apply where no exempt income is received or receivable during relevant previous year. There being gross delay of 597 days in filing SLP by revenue which had not been explained,  SLP was  dismissed on ground of delay.  (AY. 2012-13,  2013-14)