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    <title>2021 (12) TMI 1136 - ITAT AHMEDABAD</title>
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    <description>No disallowance under section 14A read with rule 8D is sustainable where no exempt income is earned, even if the assessee has made a voluntary estimate-based disallowance. Interest cannot be proportionately disallowed on capital advances when the assessee&#039;s own funds exceed the advances and the advance is presumed to have been made from those funds. For section 80IA, the assessee&#039;s chosen initial assessment year governs computation, and losses or depreciation already absorbed before that year cannot be notionally brought forward again. Expenditure incurred to maintain vacant land around a windmill for efficient operation may form part of the depreciable cost where it has a direct operational nexus and has been consistently treated as such.</description>
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      <description>No disallowance under section 14A read with rule 8D is sustainable where no exempt income is earned, even if the assessee has made a voluntary estimate-based disallowance. Interest cannot be proportionately disallowed on capital advances when the assessee&#039;s own funds exceed the advances and the advance is presumed to have been made from those funds. For section 80IA, the assessee&#039;s chosen initial assessment year governs computation, and losses or depreciation already absorbed before that year cannot be notionally brought forward again. Expenditure incurred to maintain vacant land around a windmill for efficient operation may form part of the depreciable cost where it has a direct operational nexus and has been consistently treated as such.</description>
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      <pubDate>Thu, 23 Dec 2021 00:00:00 +0530</pubDate>
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