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    <title>2025 (10) TMI 1286 - ITAT CHANDIGARH</title>
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    <description>ITAT, Chandigarh (AT) allowed the appeal. Disallowance under s.14A read with r.8D was deleted as assessee&#039;s own funds exceeded investments, permitting presumption investments were from own funds. Addition for excessive commission was rejected where rates were board-approved, longstanding and parties not related. Interest disallowances under s.36(1)(iii) on inter-company balances were deleted as regular business transactions, and suo-moto disallowances made in the return under r.8D(2)(ii)/(iii) were directed to be deleted or restricted. Rule 8D(2)(iii) computation is to include only investments that yielded exempt income; AO directed to verify calculations and delete resulting excessive additions. Advances to group concerns treated as commercial expediency; related interest disallowances deleted.</description>
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    <pubDate>Mon, 08 Sep 2025 00:00:00 +0530</pubDate>
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      <title>2025 (10) TMI 1286 - ITAT CHANDIGARH</title>
      <link>https://www.taxtmi.com/caselaws?id=780489</link>
      <description>ITAT, Chandigarh (AT) allowed the appeal. Disallowance under s.14A read with r.8D was deleted as assessee&#039;s own funds exceeded investments, permitting presumption investments were from own funds. Addition for excessive commission was rejected where rates were board-approved, longstanding and parties not related. Interest disallowances under s.36(1)(iii) on inter-company balances were deleted as regular business transactions, and suo-moto disallowances made in the return under r.8D(2)(ii)/(iii) were directed to be deleted or restricted. Rule 8D(2)(iii) computation is to include only investments that yielded exempt income; AO directed to verify calculations and delete resulting excessive additions. Advances to group concerns treated as commercial expediency; related interest disallowances deleted.</description>
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      <pubDate>Mon, 08 Sep 2025 00:00:00 +0530</pubDate>
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