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    <title>2015 (11) TMI 392 - GUJARAT HIGH COURT</title>
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    <description>The HC upheld the ITAT&#039;s deletion of the disallowance of interest expenses under section 14A read with rule 8D, rejecting the AO&#039;s claim that the assessee failed to prove investments were made from interest-free funds. The court found the CIT(A) and ITAT&#039;s findings favorable to the assessee and declined to follow contrary precedent cited by the Revenue. Regarding disallowance under section 40(a)(ia) for non-deduction of TDS on overseas freight payments, the HC agreed with the ITAT that such payments to a non-resident shipping company do not fall under sections 194C or 194, thus deleting the disallowance. Both issues were decided against the Revenue.</description>
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    <pubDate>Mon, 27 Apr 2015 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=267583</link>
      <description>The HC upheld the ITAT&#039;s deletion of the disallowance of interest expenses under section 14A read with rule 8D, rejecting the AO&#039;s claim that the assessee failed to prove investments were made from interest-free funds. The court found the CIT(A) and ITAT&#039;s findings favorable to the assessee and declined to follow contrary precedent cited by the Revenue. Regarding disallowance under section 40(a)(ia) for non-deduction of TDS on overseas freight payments, the HC agreed with the ITAT that such payments to a non-resident shipping company do not fall under sections 194C or 194, thus deleting the disallowance. Both issues were decided against the Revenue.</description>
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      <pubDate>Mon, 27 Apr 2015 00:00:00 +0530</pubDate>
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