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    <title>2026 (1) TMI 877 - ITAT RAJKOT</title>
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    <description>Revision under section 263 failed because the assessment order was neither erroneous nor prejudicial to the interests of revenue on the issues raised. Disallowance under section 14A could not be sustained where no exempt income was earned during the year. The proposed interest disallowance under section 36(1)(iii) also failed because the alleged advances were made in earlier years and the assessee had sufficient own interest-free funds, so diversion of current-year borrowed funds was not established. The revisional order was therefore quashed and the assessment restored to that extent in favour of the assessee.</description>
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    <pubDate>Thu, 08 Jan 2026 00:00:00 +0530</pubDate>
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      <title>2026 (1) TMI 877 - ITAT RAJKOT</title>
      <link>https://www.taxtmi.com/caselaws?id=785121</link>
      <description>Revision under section 263 failed because the assessment order was neither erroneous nor prejudicial to the interests of revenue on the issues raised. Disallowance under section 14A could not be sustained where no exempt income was earned during the year. The proposed interest disallowance under section 36(1)(iii) also failed because the alleged advances were made in earlier years and the assessee had sufficient own interest-free funds, so diversion of current-year borrowed funds was not established. The revisional order was therefore quashed and the assessment restored to that extent in favour of the assessee.</description>
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      <pubDate>Thu, 08 Jan 2026 00:00:00 +0530</pubDate>
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