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    <title>2025 (10) TMI 901 - ITAT DELHI</title>
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    <description>ITAT DELHI - AT allowed most assessee grounds: Section 14A disallowance was deleted as assessee had itself excluded related expenses and AO&#039;s satisfaction was treated as recorded; interest disallowance under r.8D(2)(ii) and administrative-cost apportionment limited to investments that actually yielded exempt dividends were set aside. Weighted deduction under s.35(2AB) for Rohtak unit was allowed. Provisional liability for FPI-OE components, sharing of group resources, CSR expenditures, and classification of mutual-fund/share gains as capital (not business) were allowed. Additions under s.40(a)(i)/s.195 for purchases from parent were deleted and transfer-pricing/TPO issues directed for technical evaluation. Several indirect-tax and duty claims decided in assessee&#039;s favor or remitted per HC/SC precedents.</description>
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      <description>ITAT DELHI - AT allowed most assessee grounds: Section 14A disallowance was deleted as assessee had itself excluded related expenses and AO&#039;s satisfaction was treated as recorded; interest disallowance under r.8D(2)(ii) and administrative-cost apportionment limited to investments that actually yielded exempt dividends were set aside. Weighted deduction under s.35(2AB) for Rohtak unit was allowed. Provisional liability for FPI-OE components, sharing of group resources, CSR expenditures, and classification of mutual-fund/share gains as capital (not business) were allowed. Additions under s.40(a)(i)/s.195 for purchases from parent were deleted and transfer-pricing/TPO issues directed for technical evaluation. Several indirect-tax and duty claims decided in assessee&#039;s favor or remitted per HC/SC precedents.</description>
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