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    <title>2024 (7) TMI 832 - ITAT MUMBAI</title>
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    <description>The ITAT Mumbai allowed the assessee&#039;s appeal partly for AY 1999-2000. The tribunal directed recomputation of deduction u/s 36(1)(viii) excluding interest income from housing finance for non-residential purposes, following precedent from AY 1998-99. Expenses allocation was modified from arbitrary 80:20 ratio to actual ratio based on eligible/ineligible business income. No disallowance was required u/s 14A for tax-free bonds as assessee had sufficient own funds. Non-compete fees received were held as capital receipts not taxable since amendment u/s 28(va) applied prospectively from 2003. Stock option discount amortization was allowed as deduction following judicial precedents.</description>
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      <description>The ITAT Mumbai allowed the assessee&#039;s appeal partly for AY 1999-2000. The tribunal directed recomputation of deduction u/s 36(1)(viii) excluding interest income from housing finance for non-residential purposes, following precedent from AY 1998-99. Expenses allocation was modified from arbitrary 80:20 ratio to actual ratio based on eligible/ineligible business income. No disallowance was required u/s 14A for tax-free bonds as assessee had sufficient own funds. Non-compete fees received were held as capital receipts not taxable since amendment u/s 28(va) applied prospectively from 2003. Stock option discount amortization was allowed as deduction following judicial precedents.</description>
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