Court held that ad hoc disallowance of 2.5 per cent could not be made of dividend income as expenditure incurred on exempt income, when assessee had identified expenditure to be disallowed. Followed Godrej & Boyce Manufacturing Company Ltd. v. Dy. CIT [2017] 394 ITR 449 (SC) (AY. 2006-07)
Wipro Ltd. v. Addl. CIT (2021) 279 Taxman 203 (Karn.)(HC)
S. 14A : Disallowance of expenditure-Exempt income-Ad-hoc disallowance cannot be made.