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    <title>2016 (8) TMI 1442 - ITAT MUMBAI</title>
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    <description>Section 14A disallowance read with rule 8D was held unsustainable where the assessee was taxed under the Tonnage Tax Scheme and had not claimed any expenditure against non-shipping income. The special computation regime under Chapter XIIG applies a presumptive method for qualifying ship operations, so normal disallowance principles do not operate in the same manner. The record further showed no expenditure claimed against exempt income and investments supported by own funds, leaving no factual basis to attribute expenditure to dividend income. The disallowance was deleted in favour of the assessee.</description>
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    <pubDate>Wed, 03 Aug 2016 00:00:00 +0530</pubDate>
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      <title>2016 (8) TMI 1442 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=281600</link>
      <description>Section 14A disallowance read with rule 8D was held unsustainable where the assessee was taxed under the Tonnage Tax Scheme and had not claimed any expenditure against non-shipping income. The special computation regime under Chapter XIIG applies a presumptive method for qualifying ship operations, so normal disallowance principles do not operate in the same manner. The record further showed no expenditure claimed against exempt income and investments supported by own funds, leaving no factual basis to attribute expenditure to dividend income. The disallowance was deleted in favour of the assessee.</description>
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      <pubDate>Wed, 03 Aug 2016 00:00:00 +0530</pubDate>
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