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    <title>2021 (6) TMI 258 - ITAT DELHI</title>
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    <description>Cash freight payments attracted section 40A(3) only to the extent they were made to transporters and truck operators, while similar items linked to capital expenditure depreciation were not disallowed on identical facts. Section 14A read with Rule 8D required recalculation because the exempt income base was wrongly taken, and only the investment yielding exempt income could be considered after verification. Under section 40(a)(ia), disallowance survived for non-deduction of TDS but not for short-deduction. Alleged undisclosed sales and stock difference were rejected because the books were accepted and no independent evidence supported an addition. Deduction under section 80IB(11A) was allowed as the integrated handling, storage and transportation activity satisfied the statutory conditions.</description>
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      <link>https://www.taxtmi.com/caselaws?id=408362</link>
      <description>Cash freight payments attracted section 40A(3) only to the extent they were made to transporters and truck operators, while similar items linked to capital expenditure depreciation were not disallowed on identical facts. Section 14A read with Rule 8D required recalculation because the exempt income base was wrongly taken, and only the investment yielding exempt income could be considered after verification. Under section 40(a)(ia), disallowance survived for non-deduction of TDS but not for short-deduction. Alleged undisclosed sales and stock difference were rejected because the books were accepted and no independent evidence supported an addition. Deduction under section 80IB(11A) was allowed as the integrated handling, storage and transportation activity satisfied the statutory conditions.</description>
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