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    <title>2017 (3) TMI 1463 - ITAT AHMEDABAD</title>
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    <description>Tax additions and disallowances must rest on evidence and a legally sustainable nexus, not on surmise or conjecture. Where the assessee had sufficient interest-free funds, the section 14A disallowance was confined to the exempt income despite an unproven direct nexus between funds and investments. Alleged post-search on-money receipts could not be added without cogent documentary support or independent enquiry, and extrapolation based on suspicion was rejected. Interest disallowance under section 36(1)(iii) was also deleted because the availability of interest-free funds and the assessee&#039;s commercial expediency in making advances were not displaced by the assessment authority&#039;s view.</description>
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      <link>https://www.taxtmi.com/caselaws?id=340960</link>
      <description>Tax additions and disallowances must rest on evidence and a legally sustainable nexus, not on surmise or conjecture. Where the assessee had sufficient interest-free funds, the section 14A disallowance was confined to the exempt income despite an unproven direct nexus between funds and investments. Alleged post-search on-money receipts could not be added without cogent documentary support or independent enquiry, and extrapolation based on suspicion was rejected. Interest disallowance under section 36(1)(iii) was also deleted because the availability of interest-free funds and the assessee&#039;s commercial expediency in making advances were not displaced by the assessment authority&#039;s view.</description>
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