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    <title>2024 (12) TMI 380 - ITAT AHMEDABAD</title>
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    <description>A BIFR-sanctioned rehabilitation scheme that expressly granted relief from the operation of section 72(3) was treated as overriding the restrictive tax rule on brought-forward business loss set-off, so the assessee was entitled to the benefit where the scheme had been approved after the Income-tax Department&#039;s views were considered. On section 14A, the interest-related disallowance was not sustainable because the assessee had sufficient interest-free funds in relation to the investments, but the administrative expenditure disallowance was maintained because no supporting material was produced to rebut it. The discussion therefore records partial relief on loss set-off and interest expenditure, with the administrative disallowance left intact.</description>
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      <link>https://www.taxtmi.com/caselaws?id=762800</link>
      <description>A BIFR-sanctioned rehabilitation scheme that expressly granted relief from the operation of section 72(3) was treated as overriding the restrictive tax rule on brought-forward business loss set-off, so the assessee was entitled to the benefit where the scheme had been approved after the Income-tax Department&#039;s views were considered. On section 14A, the interest-related disallowance was not sustainable because the assessee had sufficient interest-free funds in relation to the investments, but the administrative expenditure disallowance was maintained because no supporting material was produced to rebut it. The discussion therefore records partial relief on loss set-off and interest expenditure, with the administrative disallowance left intact.</description>
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