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    <title>2023 (6) TMI 83 - ITAT DELHI</title>
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    <description>Income from sale of sugar cane seeds cultivated on the assessee&#039;s own agricultural land was treated as agricultural income exempt under section 10(1), and the Revenue&#039;s challenge failed because the factual position had been accepted in earlier years without material change. Outstanding sundry creditors were not taxable under section 41(1) because mere outstanding balances do not establish remission or cessation of liability; the liabilities remained in the books and no corresponding benefit was shown. Disallowance under Rule 8D(2)(iii) had to be restricted to investments that actually yielded exempt income, so the wider computation was rejected and the deletion of the excess disallowance was upheld.</description>
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      <title>2023 (6) TMI 83 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=438509</link>
      <description>Income from sale of sugar cane seeds cultivated on the assessee&#039;s own agricultural land was treated as agricultural income exempt under section 10(1), and the Revenue&#039;s challenge failed because the factual position had been accepted in earlier years without material change. Outstanding sundry creditors were not taxable under section 41(1) because mere outstanding balances do not establish remission or cessation of liability; the liabilities remained in the books and no corresponding benefit was shown. Disallowance under Rule 8D(2)(iii) had to be restricted to investments that actually yielded exempt income, so the wider computation was rejected and the deletion of the excess disallowance was upheld.</description>
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