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    <title>2025 (2) TMI 328 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai allowed multiple claims for a housing finance company across several assessment years. The tribunal granted deduction u/s 36(1)(viii) for infrastructure loans and securitization income, holding that risk remained with the assessee despite securitization arrangements. For s.14A disallowances, no interest disallowance was warranted as owned funds exceeded tax-free investments. Administrative expenses disallowance under Rule 8D was restricted to suo moto amounts due to lack of objective satisfaction by AO. The tribunal allowed ESOS expenditure deduction, club subscription fees as revenue expenditure, and capital gains exemption u/s 54EC. Bad debts written off were allowed subject to verification against provisions created up to 2016. Penalty u/s 271(1)(c) was deleted following established precedents.</description>
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    <pubDate>Tue, 28 Jan 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=765782</link>
      <description>ITAT Mumbai allowed multiple claims for a housing finance company across several assessment years. The tribunal granted deduction u/s 36(1)(viii) for infrastructure loans and securitization income, holding that risk remained with the assessee despite securitization arrangements. For s.14A disallowances, no interest disallowance was warranted as owned funds exceeded tax-free investments. Administrative expenses disallowance under Rule 8D was restricted to suo moto amounts due to lack of objective satisfaction by AO. The tribunal allowed ESOS expenditure deduction, club subscription fees as revenue expenditure, and capital gains exemption u/s 54EC. Bad debts written off were allowed subject to verification against provisions created up to 2016. Penalty u/s 271(1)(c) was deleted following established precedents.</description>
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