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    <title>2025 (4) TMI 348 - ITAT DELHI</title>
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    <description>Business expenditure was disallowed on the premise that investment in subsidiaries was not a business activity. Relying on SC/HC precedents that holding-company investment activity can constitute business and that identical expenditure had been accepted in an earlier AY, the ITAT held the expenditure allowable and deleted the disallowance. Directors&#039; remuneration was disallowed as allegedly exceeding limits under company law; since the assessee claimed the excess had been reversed in a later FY and offered to tax, the ITAT remitted the matter to the AO for verification and recomputation. Disallowance under s.14A was held inapplicable absent exempt income, following jurisdictional HC rulings holding the later amendment prospective; the disallowance was deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=768434</link>
      <description>Business expenditure was disallowed on the premise that investment in subsidiaries was not a business activity. Relying on SC/HC precedents that holding-company investment activity can constitute business and that identical expenditure had been accepted in an earlier AY, the ITAT held the expenditure allowable and deleted the disallowance. Directors&#039; remuneration was disallowed as allegedly exceeding limits under company law; since the assessee claimed the excess had been reversed in a later FY and offered to tax, the ITAT remitted the matter to the AO for verification and recomputation. Disallowance under s.14A was held inapplicable absent exempt income, following jurisdictional HC rulings holding the later amendment prospective; the disallowance was deleted.</description>
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