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    <title>Partial disallowance where taxpayer borrowed at 12% and lent at 5%; AO to compute 7% disallowance and reassess under s.234A</title>
    <link>https://www.taxtmi.com/highlights?id=92040</link>
    <description>The ITAT upheld in part the AO&#039;s disallowance: where the assessee borrowed at 12% and advanced interest-bearing loans at 5% to five related entities, a 7% interest disallowance is warranted and the AO is directed to compute and quantify that disallowance. For other advances, the ITAT required the assessee to produce a cash-flow statement and full particulars of loans squared-off to enable the AO to segregate interest-bearing funds from interest-free funds; disallowance is to be computed only to the extent interest-bearing funds were advanced interest-free. The AO must also reassess interest under section 234A only from the extended filing due date.</description>
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    <pubDate>Fri, 29 Aug 2025 08:56:29 +0530</pubDate>
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      <title>Partial disallowance where taxpayer borrowed at 12% and lent at 5%; AO to compute 7% disallowance and reassess under s.234A</title>
      <link>https://www.taxtmi.com/highlights?id=92040</link>
      <description>The ITAT upheld in part the AO&#039;s disallowance: where the assessee borrowed at 12% and advanced interest-bearing loans at 5% to five related entities, a 7% interest disallowance is warranted and the AO is directed to compute and quantify that disallowance. For other advances, the ITAT required the assessee to produce a cash-flow statement and full particulars of loans squared-off to enable the AO to segregate interest-bearing funds from interest-free funds; disallowance is to be computed only to the extent interest-bearing funds were advanced interest-free. The AO must also reassess interest under section 234A only from the extended filing due date.</description>
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      <pubDate>Fri, 29 Aug 2025 08:56:29 +0530</pubDate>
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