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    <title>2026 (1) TMI 350 - ITAT PUNE</title>
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    <description>Disallowance under s.14A was examined on whether the AO could reject the assessee&#039;s working without recording satisfaction as mandated by s.14A(2). As the AO neither controverted the assessee&#039;s detailed computation from the books nor recorded proper dissatisfaction, the disallowance was unsustainable; the deletion by the CIT(A) was upheld. On MAT under s.115JB, the addition of the s.14A disallowance to book profit was held impermissible, following binding precedent and the view taken in the assessee&#039;s earlier year; the MAT adjustment was rejected. On weighted deduction under s.35(2AB), denial merely for non-availability of Form 3CL during assessment was unjustified once subsequently issued by DSIR; the CIT(A)&#039;s allowance was sustained and the Revenue&#039;s appeal was dismissed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=784594</link>
      <description>Disallowance under s.14A was examined on whether the AO could reject the assessee&#039;s working without recording satisfaction as mandated by s.14A(2). As the AO neither controverted the assessee&#039;s detailed computation from the books nor recorded proper dissatisfaction, the disallowance was unsustainable; the deletion by the CIT(A) was upheld. On MAT under s.115JB, the addition of the s.14A disallowance to book profit was held impermissible, following binding precedent and the view taken in the assessee&#039;s earlier year; the MAT adjustment was rejected. On weighted deduction under s.35(2AB), denial merely for non-availability of Form 3CL during assessment was unjustified once subsequently issued by DSIR; the CIT(A)&#039;s allowance was sustained and the Revenue&#039;s appeal was dismissed.</description>
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