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    <title>2019 (12) TMI 958 - ITAT KOLKATA</title>
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    <description>Section 14A read with rule 8D was applied only to investments that actually yielded exempt income, and interest disallowance was not sustained where sufficient own funds were available; the direct expenditure component remained. Prior period expenses were deductible in the year the liability crystallised on receipt and settlement of bills. Notional interest on an interest-free advance to a subsidiary was not disallowed where the advance was for business purposes and out of own funds. Compensation paid to a related party for vacating premises was treated as a genuine business outlay, not excessive payment. Government securities were held distinct from bonds or debentures for the third proviso to section 48, so indexation could not be denied. Education cess was treated as deductible business expenditure under section 37(1), subject to verification.</description>
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      <title>2019 (12) TMI 958 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=390075</link>
      <description>Section 14A read with rule 8D was applied only to investments that actually yielded exempt income, and interest disallowance was not sustained where sufficient own funds were available; the direct expenditure component remained. Prior period expenses were deductible in the year the liability crystallised on receipt and settlement of bills. Notional interest on an interest-free advance to a subsidiary was not disallowed where the advance was for business purposes and out of own funds. Compensation paid to a related party for vacating premises was treated as a genuine business outlay, not excessive payment. Government securities were held distinct from bonds or debentures for the third proviso to section 48, so indexation could not be denied. Education cess was treated as deductible business expenditure under section 37(1), subject to verification.</description>
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