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    <description>Corporate guarantee commission for associated enterprises was benchmarked at 0.5% rather than 1.75%, on the basis that corporate guarantee fees are not comparable to bank guarantee charges and the lower rate had been accepted in earlier authorities. Interest subsidy under the Technology Upgradation Fund Scheme was tested by its purpose and treated as a capital receipt because it promoted modernization and competitiveness; it was therefore not chargeable to tax and was also excluded from book profit under section 115JB. For section 14A, disallowance of interest was deleted where the investments were strategic and sufficient interest-free funds were available, while the administrative component under rule 8D was restored for recomputation.</description>
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