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    <description>Interest on delayed receivables from an associated enterprise was benchmarked at LIBOR plus 0.5%, and the higher transfer pricing adjustment was reduced. Interest on margin money was treated as business income, while interest on bank deposits and inter-corporate deposits was assessed as income from other sources. Disallowance under section 14A read with Rule 8D was held unsustainable in the absence of exempt income, including for book profit under section 115JB. The addition for provision for income tax recoverable was sustained in normal computation but deleted for book profit. No notional interest could be imputed on share application money advanced to an associated enterprise absent evidence of a sham arrangement.</description>
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