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    <title>2025 (11) TMI 1313 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai partly allowed the assessee&#039;s appeal. On disallowance under s.14A r/w Rule 8D, the Tribunal held that no direct expenditure was incurred to earn exempt income and directed the AO to restrict disallowance to the expenditure voluntarily claimed by the assessee, after verification, thus partly allowing that ground for statistical purposes. On the issue of excess refund, the Tribunal noted that payments between the HUF assessee and its karta in his individual capacity were in the nature of advances. The excess refund received was held to be a capital receipt, not taxable as income, and the addition made by the AO was deleted.</description>
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      <title>2025 (11) TMI 1313 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=781845</link>
      <description>ITAT Mumbai partly allowed the assessee&#039;s appeal. On disallowance under s.14A r/w Rule 8D, the Tribunal held that no direct expenditure was incurred to earn exempt income and directed the AO to restrict disallowance to the expenditure voluntarily claimed by the assessee, after verification, thus partly allowing that ground for statistical purposes. On the issue of excess refund, the Tribunal noted that payments between the HUF assessee and its karta in his individual capacity were in the nature of advances. The excess refund received was held to be a capital receipt, not taxable as income, and the addition made by the AO was deleted.</description>
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