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    <title>2017 (7) TMI 1302 - ITAT DELHI</title>
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    <description>Disputed customer security deposits required reconciliation before any related interest disallowance could be sustained, so the matter was sent back for fresh adjudication. Disallowance under section 14A read with Rule 8D was found unsustainable where the assessee had sufficient own funds and no borrowed funds were shown to have been used for the investments, making mechanical application of Rule 8D impermissible. An addition based on understatement of income arising from a change in accounting policy was also deleted because the accounting changes complied with prevailing standards and could not be selectively rejected merely for adverse tax effect.</description>
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      <link>https://www.taxtmi.com/caselaws?id=281321</link>
      <description>Disputed customer security deposits required reconciliation before any related interest disallowance could be sustained, so the matter was sent back for fresh adjudication. Disallowance under section 14A read with Rule 8D was found unsustainable where the assessee had sufficient own funds and no borrowed funds were shown to have been used for the investments, making mechanical application of Rule 8D impermissible. An addition based on understatement of income arising from a change in accounting policy was also deleted because the accounting changes complied with prevailing standards and could not be selectively rejected merely for adverse tax effect.</description>
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