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    <description>Reserve utilisation under section 80HHD(4) was upheld where the investment was made by subscription to equity shares of a hotel company formed for a new hotel project, with no material showing diversion beyond the statutory objects; the disallowance was therefore unjustified. Notional interest on an outstanding balance due from a subsidiary was rejected because there was no legal or contractual basis requiring interest to be charged, and taxable income could not be imputed on that footing. Rental income from letting out a hotel terrace was treated as business income, since the terrace formed part of the commercial hotel asset and was exploited in the course of the hotel business.</description>
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