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    <title>2020 (7) TMI 170 - ITAT PUNE</title>
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    <description>No disallowance under section 14A read with Rule 8D was sustained because the assessee earned no exempt income, so the factual basis for attribution of expenditure was absent. Deduction under section 80IA(4) was treated as available for business-linked undisclosed income from search and for receipts with established infrastructure-business nexus; miscellaneous receipts already covered by earlier order were allowed, while the balance required factual verification. Seized cash was held adjustable against existing tax liability for the relevant pre-amendment period, and the corresponding interest under section 234B was not sustained. Cash found with the individual was not taxed as unexplained income because search evidence showed it belonged to the company.</description>
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      <link>https://www.taxtmi.com/caselaws?id=396501</link>
      <description>No disallowance under section 14A read with Rule 8D was sustained because the assessee earned no exempt income, so the factual basis for attribution of expenditure was absent. Deduction under section 80IA(4) was treated as available for business-linked undisclosed income from search and for receipts with established infrastructure-business nexus; miscellaneous receipts already covered by earlier order were allowed, while the balance required factual verification. Seized cash was held adjustable against existing tax liability for the relevant pre-amendment period, and the corresponding interest under section 234B was not sustained. Cash found with the individual was not taxed as unexplained income because search evidence showed it belonged to the company.</description>
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