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    <title>2023 (2) TMI 198 - ITAT KOLKATA</title>
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    <description>Cash deposits supported by bank statements and a verifiable cash-flow trail were treated as explained, because repeated withdrawals and redeposits, without any negative cash balance or proof that the cash was deployed elsewhere, did not justify an addition as unexplained money under section 69A. Interest paid on cash credit borrowing was not deductible against fixed-deposit interest under section 57(3), because the expenditure was not shown to have been incurred wholly and exclusively for earning that income. For a UAE resident, the India-UAE DTAA applied to fixed-deposit interest and the treaty-capped rate of 12.5 per cent governed the Indian tax charge on that income.</description>
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      <link>https://www.taxtmi.com/caselaws?id=433683</link>
      <description>Cash deposits supported by bank statements and a verifiable cash-flow trail were treated as explained, because repeated withdrawals and redeposits, without any negative cash balance or proof that the cash was deployed elsewhere, did not justify an addition as unexplained money under section 69A. Interest paid on cash credit borrowing was not deductible against fixed-deposit interest under section 57(3), because the expenditure was not shown to have been incurred wholly and exclusively for earning that income. For a UAE resident, the India-UAE DTAA applied to fixed-deposit interest and the treaty-capped rate of 12.5 per cent governed the Indian tax charge on that income.</description>
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