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    <title>2022 (8) TMI 861 - ITAT CHENNAI</title>
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    <description>Strategic investments are not excluded when computing disallowance under section 14A read with Rule 8D, so the disallowance was revised to that extent, while the directions on surplus funds remained unchanged. A share sale in a promoter-exit context was not treated as a colourable device because the higher benchmark sale price was not shown to reflect the actual consideration, and the addition was deleted. A buy-back of shares carried out under the applicable corporate restructuring and valuation framework was likewise not regarded as a colourable device, so the related capital loss disallowance was not sustained.</description>
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      <title>2022 (8) TMI 861 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=426622</link>
      <description>Strategic investments are not excluded when computing disallowance under section 14A read with Rule 8D, so the disallowance was revised to that extent, while the directions on surplus funds remained unchanged. A share sale in a promoter-exit context was not treated as a colourable device because the higher benchmark sale price was not shown to reflect the actual consideration, and the addition was deleted. A buy-back of shares carried out under the applicable corporate restructuring and valuation framework was likewise not regarded as a colourable device, so the related capital loss disallowance was not sustained.</description>
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