In Brief
This landmark judgment addresses whether expenditure incurred to acquire shares—particularly for retaining control or as trading assets—that generate exempt dividend income can be deducted under tax law. The Supreme Court held that when shares are held as investment for control purposes, the expenditure (including interest on borrowed funds) is attributable to earning dividend income, and apportionment applies despite the dominant purpose being control rather than dividends. The dominant intention test was rejected. For shares held as stock-in-trade where dividend is incidental, apportionment may still apply. The Court clarified that Section 14A operates on apportionment principles to prevent double benefit: exemption of income plus deduction of related expenditure.
The lawyer headnote and full judgment text are available to registered users.