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    <title>2025 (12) TMI 1359 - BOMBAY HIGH COURT</title>
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    <description>The dominant issue was whether the Revenue&#039;s appeal against deletion of disallowance under s.57(iii) was maintainable and raised any substantial question of law. Based on the AO&#039;s remand report accepting allowability of most expenditure and limiting the dispute to a smaller amount, the HC held the tax effect fell below the CBDT monetary threshold, resulting in dismissal for low tax effect. Independently, the HC held the CIT(A)&#039;s finding of a direct nexus between income earned and expenditure incurred was a pure finding of fact, affirmed by the ITAT, and therefore no question of law arose; the appeal was dismissed.</description>
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      <description>The dominant issue was whether the Revenue&#039;s appeal against deletion of disallowance under s.57(iii) was maintainable and raised any substantial question of law. Based on the AO&#039;s remand report accepting allowability of most expenditure and limiting the dispute to a smaller amount, the HC held the tax effect fell below the CBDT monetary threshold, resulting in dismissal for low tax effect. Independently, the HC held the CIT(A)&#039;s finding of a direct nexus between income earned and expenditure incurred was a pure finding of fact, affirmed by the ITAT, and therefore no question of law arose; the appeal was dismissed.</description>
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