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    <description>Section 14A disallowance under Rule 8D(2)(iii) requires the Assessing Officer to record objective dissatisfaction based on the accounts; a mechanical reference to earlier years is insufficient. Payments for RBI non-compliance and regulatory breaches were treated as compensatory regulatory charges, not expenditure for an offence or prohibited purpose under section 37(1). For section 115JB, employer tax borne on non-monetary perquisites was treated as part of employee cost and not as a permitted book-profit adjustment. Year-end provisions for accrued expenses were not disallowed under section 40(a)(ia) where liability had crystallised and tax was deducted when payees were identified. Education cess and higher and secondary education cess were held allowable as business deduction.</description>
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