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    <title>2023 (8) TMI 1058 - ITAT MUMBAI</title>
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    <description>Rule 8D disallowance under section 14A was confined to investments that actually yielded exempt income, and no interest disallowance was justified where the assessee&#039;s own funds exceeded tax-free investments. Replacement of meters was treated as revenue expenditure because it only improved business efficiency without creating an enduring asset. Head office expenses were not allocated to the eligible unit for section 80IA where no direct nexus was shown, and deduction under section 80IA was not restricted to gross total income in the manner urged by the Revenue. No further addition under section 14A was permissible in computing book profit under section 115JB, and the estimated disallowance for inflated coal expenses was deleted as unsupported by sustainable adverse material.</description>
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      <description>Rule 8D disallowance under section 14A was confined to investments that actually yielded exempt income, and no interest disallowance was justified where the assessee&#039;s own funds exceeded tax-free investments. Replacement of meters was treated as revenue expenditure because it only improved business efficiency without creating an enduring asset. Head office expenses were not allocated to the eligible unit for section 80IA where no direct nexus was shown, and deduction under section 80IA was not restricted to gross total income in the manner urged by the Revenue. No further addition under section 14A was permissible in computing book profit under section 115JB, and the estimated disallowance for inflated coal expenses was deleted as unsupported by sustainable adverse material.</description>
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