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    <title>2026 (1) TMI 756 - ITAT KOLKATA</title>
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    <description>Allowability of club subscription was examined on whether such expenses are personal or wholly and exclusively for business; absence of inquiry by the AO and lack of reasoning for a 50% disallowance led the tribunal to delete the entire addition, relying on precedents rejecting estimation and presumption. Disallowance of expenditures attributable to earning exempt income must be restricted to amounts allocable to those exempt investments; the tribunal set aside the appellate order and directed the AO to confine disallowance to exempt income only. Addition of such disallowance to book profit for MAT computation was found impermissible and disallowed as increasing MAT book profit by adjustments not authorised for that purpose.</description>
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    <pubDate>Tue, 13 Jan 2026 00:00:00 +0530</pubDate>
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      <title>2026 (1) TMI 756 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=785000</link>
      <description>Allowability of club subscription was examined on whether such expenses are personal or wholly and exclusively for business; absence of inquiry by the AO and lack of reasoning for a 50% disallowance led the tribunal to delete the entire addition, relying on precedents rejecting estimation and presumption. Disallowance of expenditures attributable to earning exempt income must be restricted to amounts allocable to those exempt investments; the tribunal set aside the appellate order and directed the AO to confine disallowance to exempt income only. Addition of such disallowance to book profit for MAT computation was found impermissible and disallowed as increasing MAT book profit by adjustments not authorised for that purpose.</description>
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