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    <title>2014 (7) TMI 853 - ITAT MUMBAI</title>
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    <description>Section 10A exemption for SEZ manufacturing profits was upheld in principle, but denied pro tanto for profit attributable to undervaluation of gold bars and for medallion labour charges where the onus was not discharged. Cash duty payment was accepted, yet cash moved from outstation branches was treated as unexplained cash credit, while the unexplained expenditure addition was deleted. Assignment-based receipts were held to be valid transfers of actionable claims, and the attempt to treat them as unexplained cash credits failed. The alleged unaccounted jewellery sale addition was deleted for want of independent evidence. Section 40(a)(ia) disallowance for short deduction was deleted, commission was remanded, and excess interest disallowance was confined to the amount above the benchmark rate. Forward contract loss in diamond trade was treated as allowable business loss.</description>
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    <pubDate>Mon, 12 May 2014 00:00:00 +0530</pubDate>
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      <title>2014 (7) TMI 853 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=249817</link>
      <description>Section 10A exemption for SEZ manufacturing profits was upheld in principle, but denied pro tanto for profit attributable to undervaluation of gold bars and for medallion labour charges where the onus was not discharged. Cash duty payment was accepted, yet cash moved from outstation branches was treated as unexplained cash credit, while the unexplained expenditure addition was deleted. Assignment-based receipts were held to be valid transfers of actionable claims, and the attempt to treat them as unexplained cash credits failed. The alleged unaccounted jewellery sale addition was deleted for want of independent evidence. Section 40(a)(ia) disallowance for short deduction was deleted, commission was remanded, and excess interest disallowance was confined to the amount above the benchmark rate. Forward contract loss in diamond trade was treated as allowable business loss.</description>
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      <pubDate>Mon, 12 May 2014 00:00:00 +0530</pubDate>
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