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    <title>2021 (1) TMI 74 - ITAT MUMBAI</title>
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    <description>ITAT MUMBAI upheld partial disallowance under s.14A but remitted the matter to the AO to reassess the sufficiency of the allowance for consistency with earlier Tribunal directions. Transfer pricing adjustment for interest on share-application money was deleted, treated as capital infusion not a loan. Corporate guarantee fee was accepted at 0.5%. Addition under s.43B for ESIC contributions was deleted as timely deposited. Disallowance of education cess and SHEC under s.40(a)(ii) was deleted. For capital gains on depreciable buildings, the Tribunal held s.50 does not obliterate long-term status; matter to be reexamined by AO in light of HC precedent.</description>
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      <description>ITAT MUMBAI upheld partial disallowance under s.14A but remitted the matter to the AO to reassess the sufficiency of the allowance for consistency with earlier Tribunal directions. Transfer pricing adjustment for interest on share-application money was deleted, treated as capital infusion not a loan. Corporate guarantee fee was accepted at 0.5%. Addition under s.43B for ESIC contributions was deleted as timely deposited. Disallowance of education cess and SHEC under s.40(a)(ii) was deleted. For capital gains on depreciable buildings, the Tribunal held s.50 does not obliterate long-term status; matter to be reexamined by AO in light of HC precedent.</description>
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