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    <description>Section 14A read with Rule 8D was applied restrictively where own funds exceeded investments, so no interest disallowance was warranted and administrative disallowance was limited to investments yielding exempt income; the same restricted amount was directed for book-profit adjustment under section 115JB. ESOP discount was treated as employee compensation cost and allowed as a deduction under section 37(1). Education cess and secondary higher education cess were also treated as deductible expenditure in line with the jurisdictional High Court view.</description>
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