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    <title>2025 (10) TMI 282 - ITAT KOLKATA</title>
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    <description>ITAT KOLKATA - AT allowed the appeal, setting aside the CIT(A) order. The tribunal held interest under section 36(1)(iii) cannot be proportionately disallowed because interest-free advances were presumed funded by interest-free funds, and directed the AO to delete the disallowance. Under section 14A read with Rule 8D, the disallowance cannot exceed the exempt income of Rs. 9,932 and was limited accordingly. Further, no book-profit adjustment was required for 14A/Rule 8D disallowances; the AO was directed to delete those additions.</description>
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    <pubDate>Tue, 21 Jan 2025 00:00:00 +0530</pubDate>
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      <title>2025 (10) TMI 282 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=779486</link>
      <description>ITAT KOLKATA - AT allowed the appeal, setting aside the CIT(A) order. The tribunal held interest under section 36(1)(iii) cannot be proportionately disallowed because interest-free advances were presumed funded by interest-free funds, and directed the AO to delete the disallowance. Under section 14A read with Rule 8D, the disallowance cannot exceed the exempt income of Rs. 9,932 and was limited accordingly. Further, no book-profit adjustment was required for 14A/Rule 8D disallowances; the AO was directed to delete those additions.</description>
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