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    <title>2019 (2) TMI 1721 - ITAT KOLKATA</title>
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    <description>Education cess was treated as part of income tax and therefore not allowable as a deduction in computing business income. Disallowance under section 14A was sustained because the assessee&#039;s explanation that no expenditure was incurred for exempt income was rejected, and no supporting material was produced to show sufficient interest-free funds or to disturb the restricted disallowance. Provision for non-performing assets was also not allowed in normal computation, with the reasoning linked to the RBI framework and the real income approach. For MAT purposes, the NPA provision was added back to book profit under section 115JB as a provision for diminution in asset value, and the retrospective amendment was noted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=284155</link>
      <description>Education cess was treated as part of income tax and therefore not allowable as a deduction in computing business income. Disallowance under section 14A was sustained because the assessee&#039;s explanation that no expenditure was incurred for exempt income was rejected, and no supporting material was produced to show sufficient interest-free funds or to disturb the restricted disallowance. Provision for non-performing assets was also not allowed in normal computation, with the reasoning linked to the RBI framework and the real income approach. For MAT purposes, the NPA provision was added back to book profit under section 115JB as a provision for diminution in asset value, and the retrospective amendment was noted.</description>
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