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    <title>2024 (12) TMI 1330 - ITAT MUMBAI</title>
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    <description>Commissioner (Appeals) could not enhance assessment by introducing personal withdrawals as a new source of income, because section 251(1) is confined to matters considered in the assessment; that addition was deleted. The exclusion of drawings was sustained on the facts, as the drawings had already been reflected in the earlier year and appeared in the balance sheet for the year under consideration. Interest expenditure was allowable under section 57(iii) because it had a direct nexus with income from other sources, so the disallowance was deleted. Interest under section 234B remained applicable, but the computation had to be recomputed after giving credit for tax deductible at source.</description>
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      <description>Commissioner (Appeals) could not enhance assessment by introducing personal withdrawals as a new source of income, because section 251(1) is confined to matters considered in the assessment; that addition was deleted. The exclusion of drawings was sustained on the facts, as the drawings had already been reflected in the earlier year and appeared in the balance sheet for the year under consideration. Interest expenditure was allowable under section 57(iii) because it had a direct nexus with income from other sources, so the disallowance was deleted. Interest under section 234B remained applicable, but the computation had to be recomputed after giving credit for tax deductible at source.</description>
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