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    <title>Company investments and subsidies: s14A interest disallowance barred with surplus funds; industrial subsidies treated capital, MAT additions denied</title>
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    <description>Disallowance under s.14A r.w. Rule 8D(2)(ii) was held impermissible because the assessee established availability of surplus own funds for making investments yielding exempt income; hence no interest disallowance could be attributed to such investments, and the disallowance was deleted. Disallowance under Rule 8D(2)(iii) was held untenable absent the AO&#039;s recorded objective satisfaction, as mandated by s.14A and settled law; the direction to recompute based on proper satisfaction was sustained. Sales tax and power subsidies were treated as capital receipts since the dominant purpose was industrial development and employment generation; addition to book profit u/s 115JB was rejected. Additional depreciation and bad-debt write-off/provision t.....</description>
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    <pubDate>Mon, 12 Jan 2026 16:56:31 +0530</pubDate>
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      <title>Company investments and subsidies: s14A interest disallowance barred with surplus funds; industrial subsidies treated capital, MAT additions denied</title>
      <link>https://www.taxtmi.com/highlights?id=95960</link>
      <description>Disallowance under s.14A r.w. Rule 8D(2)(ii) was held impermissible because the assessee established availability of surplus own funds for making investments yielding exempt income; hence no interest disallowance could be attributed to such investments, and the disallowance was deleted. Disallowance under Rule 8D(2)(iii) was held untenable absent the AO&#039;s recorded objective satisfaction, as mandated by s.14A and settled law; the direction to recompute based on proper satisfaction was sustained. Sales tax and power subsidies were treated as capital receipts since the dominant purpose was industrial development and employment generation; addition to book profit u/s 115JB was rejected. Additional depreciation and bad-debt write-off/provision t.....</description>
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