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    <title>2026 (2) TMI 939 - ITAT KOLKATA</title>
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    <description>Disallowance under the income-tax rule framework was addressed by treating computation method as determinative: Rule 8D application should be confined to investments that actually yielded exempt income, and the disallowance must be recalculated on the average of such investments. On recalculation and after permitting a suo-moto deduction, the net disallowance was reduced and the assessing officer was directed to restrict the addition accordingly, with reliance on higher-court precedent for the same proposition. The appeal was partly allowed in favour of the taxpayer.</description>
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      <description>Disallowance under the income-tax rule framework was addressed by treating computation method as determinative: Rule 8D application should be confined to investments that actually yielded exempt income, and the disallowance must be recalculated on the average of such investments. On recalculation and after permitting a suo-moto deduction, the net disallowance was reduced and the assessing officer was directed to restrict the addition accordingly, with reliance on higher-court precedent for the same proposition. The appeal was partly allowed in favour of the taxpayer.</description>
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