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    <title>2025 (9) TMI 274 - ITAT DELHI</title>
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    <description>Additional disallowance under section 14A read with Rule 8D was deleted because the assessee&#039;s own interest-free funds exceeded the investments, so the presumption applied that the investments were made from those funds and Rule 8D(2)(ii) was not attracted. For the computation under Rule 8D(2)(iii), only dividend-yielding investments could be included. The Assessing Officer&#039;s satisfaction was also defective, as the assessment order proceeded on the incorrect basis that no disallowance had been made by the assessee. The issue was decided in favour of the assessee.</description>
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    <pubDate>Mon, 13 Jan 2025 00:00:00 +0530</pubDate>
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      <title>2025 (9) TMI 274 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=777785</link>
      <description>Additional disallowance under section 14A read with Rule 8D was deleted because the assessee&#039;s own interest-free funds exceeded the investments, so the presumption applied that the investments were made from those funds and Rule 8D(2)(ii) was not attracted. For the computation under Rule 8D(2)(iii), only dividend-yielding investments could be included. The Assessing Officer&#039;s satisfaction was also defective, as the assessment order proceeded on the incorrect basis that no disallowance had been made by the assessee. The issue was decided in favour of the assessee.</description>
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