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    <title>2025 (7) TMI 1232 - ITAT AHMEDABAD</title>
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    <description>The ITAT Ahmedabad upheld CIT(A)&#039;s deletion of contingent liability addition after the assessee provided party-wise details during appeal proceedings showing expenses for audit fees, rent, interest, freight charges, and professional fees. The AO verified these as ascertained liabilities eligible for deduction with proper TDS compliance. Similarly, the bogus purchase addition was deleted after parties responded to section 133(6) notices during remand proceedings and confirmed transactions. However, the ITAT remanded the loan processing fee matter to the AO to examine the loan&#039;s purpose, directing that if taken for working capital, it should be allowed as revenue expenditure, but if for capital assets, it must be capitalized. The section 57 disallowance of interest expenses was also remanded to determine whether borrowings were used for exempt income investments, requiring the assessee to prove investments were from own funds.</description>
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    <pubDate>Fri, 18 Jul 2025 00:00:00 +0530</pubDate>
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      <title>2025 (7) TMI 1232 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=775164</link>
      <description>The ITAT Ahmedabad upheld CIT(A)&#039;s deletion of contingent liability addition after the assessee provided party-wise details during appeal proceedings showing expenses for audit fees, rent, interest, freight charges, and professional fees. The AO verified these as ascertained liabilities eligible for deduction with proper TDS compliance. Similarly, the bogus purchase addition was deleted after parties responded to section 133(6) notices during remand proceedings and confirmed transactions. However, the ITAT remanded the loan processing fee matter to the AO to examine the loan&#039;s purpose, directing that if taken for working capital, it should be allowed as revenue expenditure, but if for capital assets, it must be capitalized. The section 57 disallowance of interest expenses was also remanded to determine whether borrowings were used for exempt income investments, requiring the assessee to prove investments were from own funds.</description>
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      <pubDate>Fri, 18 Jul 2025 00:00:00 +0530</pubDate>
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