Section 94(7) - Dividend Stripping

Dear All,

I have query relates to disallowance of loss in case of Section 94(7) attract.


Nature of the company is dealing in share, securities and other investments. Income arising is taxable under the head "Business Income". The company has received dividend on above mentioned shares during the year and same is claim as exempt. Out of above dividend, some dividend received on which loss has been occured.


Sec. 94(7) mentioned that any loss occured in the specified period and dividend received, the same to be disallowed. As per my thinking abve section is applicable when Income taxable under the head "Capital Gain". In the above facts, the income is taxable under the head "Business Income".

Will sec. 94(7) attract in case of where Income taxable under the head "Business Income"

Please guide



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