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    <title>2022 (8) TMI 1442 - ITAT MUMBAI</title>
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    <description>Disallowance under section 14A requires objective satisfaction based on the accounts before Rule 8D can be invoked, and the Rule 8D mechanism cannot be mechanically imported into book profit computation under section 115JB beyond actual expenditure relatable to exempt income. A long-term capital loss remained eligible for carry forward where non-population in the revised return was due to a system glitch. TDS credit was to be allowed, subject to verification, where tax was deducted on income already offered or deposited belatedly by the deductor. Interest disallowance on advances to an employee welfare trust was deleted because sufficient interest-free funds existed. A provision for expenses supported by evidence was treated as an ascertained liability and allowed under normal provisions and section 115JB, while the alternative capital gains computation was remanded for fresh verification.</description>
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      <description>Disallowance under section 14A requires objective satisfaction based on the accounts before Rule 8D can be invoked, and the Rule 8D mechanism cannot be mechanically imported into book profit computation under section 115JB beyond actual expenditure relatable to exempt income. A long-term capital loss remained eligible for carry forward where non-population in the revised return was due to a system glitch. TDS credit was to be allowed, subject to verification, where tax was deducted on income already offered or deposited belatedly by the deductor. Interest disallowance on advances to an employee welfare trust was deleted because sufficient interest-free funds existed. A provision for expenses supported by evidence was treated as an ascertained liability and allowed under normal provisions and section 115JB, while the alternative capital gains computation was remanded for fresh verification.</description>
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