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    <title>2018 (11) TMI 1959 - ITAT JAIPUR</title>
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    <description>Disallowance of interest under section 40(a)(ia) was considered in light of the second proviso, which was treated as curative and retrospective. Where the recipient has already included the relevant amount in total income and paid tax, the disallowance is not meant to survive in principle. The benefit, however, depends on factual verification, including supporting certificate and confirmation that the recipient offered the interest income to tax. The Assessing Officer was therefore directed to verify those facts and decide the issue accordingly.</description>
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      <description>Disallowance of interest under section 40(a)(ia) was considered in light of the second proviso, which was treated as curative and retrospective. Where the recipient has already included the relevant amount in total income and paid tax, the disallowance is not meant to survive in principle. The benefit, however, depends on factual verification, including supporting certificate and confirmation that the recipient offered the interest income to tax. The Assessing Officer was therefore directed to verify those facts and decide the issue accordingly.</description>
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      <pubDate>Tue, 27 Nov 2018 00:00:00 +0530</pubDate>
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