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    <title>2022 (11) TMI 1420 - ITAT MUMBAI</title>
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    <description>The ITAT Mumbai ruled on multiple issues in this corporate tax case. The tribunal upheld the principle of disallowance under section 14A read with rule 8D but reduced the quantum since the assessee used no borrowed funds. Sales tax and excise duty incentives were held to be capital receipts, not revenue, following established precedents including Gujarat HC&#039;s decision in Nirma Ltd. The tribunal rejected additions under section 41(1) regarding NPV differences, citing binding SC precedent in Balakrishna Industries. Community welfare expenses were allowed as business expenditure based on consistency principle from previous assessment years. Additional depreciation was permitted on eligible assets acquired before 2008, rejecting the revenue&#039;s narrow interpretation of &quot;new machinery.&quot;</description>
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      <description>The ITAT Mumbai ruled on multiple issues in this corporate tax case. The tribunal upheld the principle of disallowance under section 14A read with rule 8D but reduced the quantum since the assessee used no borrowed funds. Sales tax and excise duty incentives were held to be capital receipts, not revenue, following established precedents including Gujarat HC&#039;s decision in Nirma Ltd. The tribunal rejected additions under section 41(1) regarding NPV differences, citing binding SC precedent in Balakrishna Industries. Community welfare expenses were allowed as business expenditure based on consistency principle from previous assessment years. Additional depreciation was permitted on eligible assets acquired before 2008, rejecting the revenue&#039;s narrow interpretation of &quot;new machinery.&quot;</description>
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