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    <title>2023 (11) TMI 1192 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai directed AO to recompute book profit under section 115JB allowing brought forward losses/unabsorbed depreciation per books, resulting in nil tax liability. Share application money addition under section 68 was remanded for fresh examination considering investor&#039;s creditworthiness and genuineness. Expenditure on animated episodes and in-house production costs were allowed as revenue expenditure in the year of telecast, rejecting CIT(A)&#039;s three-year spreading formula. TDS disallowance under section 40(a)(ia) was deleted following Bombay HC precedent that retrospective amendments cannot create impossible compliance obligations. Surplus on demerger was correctly added to book profit under section 115JB. Provision for doubtful advances was properly disallowed as it represents asset diminution. Section 14A disallowance was deleted due to absence of exempt income. Professional fees for demerger were correctly allowed under section 35DD over five years. Mismatch between books and Form 26AS was remanded for reconciliation.</description>
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    <pubDate>Tue, 21 Nov 2023 00:00:00 +0530</pubDate>
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      <description>ITAT Mumbai directed AO to recompute book profit under section 115JB allowing brought forward losses/unabsorbed depreciation per books, resulting in nil tax liability. Share application money addition under section 68 was remanded for fresh examination considering investor&#039;s creditworthiness and genuineness. Expenditure on animated episodes and in-house production costs were allowed as revenue expenditure in the year of telecast, rejecting CIT(A)&#039;s three-year spreading formula. TDS disallowance under section 40(a)(ia) was deleted following Bombay HC precedent that retrospective amendments cannot create impossible compliance obligations. Surplus on demerger was correctly added to book profit under section 115JB. Provision for doubtful advances was properly disallowed as it represents asset diminution. Section 14A disallowance was deleted due to absence of exempt income. Professional fees for demerger were correctly allowed under section 35DD over five years. Mismatch between books and Form 26AS was remanded for reconciliation.</description>
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