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    <title>2025 (12) TMI 782 - ITAT MUMBAI</title>
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    <description>ITAT partly allowed the assessee&#039;s appeal. It held that the AO&#039;s disallowance under s.14A r.w.r. 8D(2)(i) and 8D(2)(ii) was vitiated for want of jurisdictional satisfaction and absence of proximate nexus with exempt income; those disallowances were deleted, and only a restricted disallowance under Rule 8D(2)(iii), confined to investments actually yielding exempt income, was sustained. The assessee&#039;s suo motu disallowance was accepted as consistent with law. Disallowances of professional fees to a foundation and expenses of the UK branch/guest house, including refurbishment by Waverly Renovation Ltd., were treated as revenue expenditure allowable u/s 37(1). However, payment for supply and installation of pumps to Vasudeva Manufacturing &amp; Engineering Pvt. Ltd. was held capital in nature, with depreciation allowable as per law.</description>
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    <pubDate>Thu, 27 Nov 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 782 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=783242</link>
      <description>ITAT partly allowed the assessee&#039;s appeal. It held that the AO&#039;s disallowance under s.14A r.w.r. 8D(2)(i) and 8D(2)(ii) was vitiated for want of jurisdictional satisfaction and absence of proximate nexus with exempt income; those disallowances were deleted, and only a restricted disallowance under Rule 8D(2)(iii), confined to investments actually yielding exempt income, was sustained. The assessee&#039;s suo motu disallowance was accepted as consistent with law. Disallowances of professional fees to a foundation and expenses of the UK branch/guest house, including refurbishment by Waverly Renovation Ltd., were treated as revenue expenditure allowable u/s 37(1). However, payment for supply and installation of pumps to Vasudeva Manufacturing &amp; Engineering Pvt. Ltd. was held capital in nature, with depreciation allowable as per law.</description>
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      <pubDate>Thu, 27 Nov 2025 00:00:00 +0530</pubDate>
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