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    <title>2025 (12) TMI 1109 - ITAT PUNE</title>
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    <description>Disallowance under s.14A for interest expenditure on investments yielding exempt income turned on whether borrowed funds were used. As the AO made no specific finding that interest-bearing funds were applied for such investments, a presumption arose that investments were made from interest-free/own funds; applying SC precedent in Reliance Industries Ltd., the Tribunal held the interest disallowance was unwarranted and deleted it. The remaining non-interest disallowance under s.14A was sustained, resulting in partial relief to the taxpayer.</description>
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      <link>https://www.taxtmi.com/caselaws?id=783569</link>
      <description>Disallowance under s.14A for interest expenditure on investments yielding exempt income turned on whether borrowed funds were used. As the AO made no specific finding that interest-bearing funds were applied for such investments, a presumption arose that investments were made from interest-free/own funds; applying SC precedent in Reliance Industries Ltd., the Tribunal held the interest disallowance was unwarranted and deleted it. The remaining non-interest disallowance under s.14A was sustained, resulting in partial relief to the taxpayer.</description>
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