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    <title>2014 (1) TMI 1699 - ITAT LUCKNOW</title>
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    <description>Where investments in subsidiaries were made from own funds and borrowed loans were used for business, no proportionate interest could be disallowed under section 14A read with Rule 8D; only the administrative component survived. On sister-concern advances, proportionate interest disallowance under section 36(1)(iii) was deleted because the issue was covered by earlier Tribunal orders and no material factual difference was shown. Expenditure for a transmission line and contribution to UPPCL was treated as revenue expenditure under section 37(1) because it conferred only a right to use the line, not ownership of an enduring asset. For section 115JB, only the amount of section 14A disallowance actually sustained on merits could be added back to book profit.</description>
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      <link>https://www.taxtmi.com/caselaws?id=178353</link>
      <description>Where investments in subsidiaries were made from own funds and borrowed loans were used for business, no proportionate interest could be disallowed under section 14A read with Rule 8D; only the administrative component survived. On sister-concern advances, proportionate interest disallowance under section 36(1)(iii) was deleted because the issue was covered by earlier Tribunal orders and no material factual difference was shown. Expenditure for a transmission line and contribution to UPPCL was treated as revenue expenditure under section 37(1) because it conferred only a right to use the line, not ownership of an enduring asset. For section 115JB, only the amount of section 14A disallowance actually sustained on merits could be added back to book profit.</description>
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