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    <title>2025 (8) TMI 1605 - ITAT KOLKATA</title>
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    <description>ITAT allowed in part. Applying s.57, it held the assessee must prove source of advances by filing a cash-flow/loan-squared-off details; where funds were borrowed at 12% and re-advanced at 5% for five entities, a 7% interest disallowance is warranted and is to be worked out by the AO. For purported interest-free advances, disallowance is limited to the portion of interest-bearing funds actually advanced interest-free, pending submission of records. AO must recompute accordingly. AO is also directed under s.234A to levy interest only from any extended due date of filing; grounds partly allowed.</description>
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      <title>2025 (8) TMI 1605 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=777417</link>
      <description>ITAT allowed in part. Applying s.57, it held the assessee must prove source of advances by filing a cash-flow/loan-squared-off details; where funds were borrowed at 12% and re-advanced at 5% for five entities, a 7% interest disallowance is warranted and is to be worked out by the AO. For purported interest-free advances, disallowance is limited to the portion of interest-bearing funds actually advanced interest-free, pending submission of records. AO must recompute accordingly. AO is also directed under s.234A to levy interest only from any extended due date of filing; grounds partly allowed.</description>
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