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    <title>2026 (3) TMI 634 - ITAT MUMBAI</title>
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    <description>Section 80JJAA allows deduction for additional employee cost over the statutory three-year period, so a later-year claim is not barred merely because the amount relates to earlier eligible years. Disallowance under section 14A read with Rule 8D requires proper dissatisfaction with the accounts, and where the assessee has made a suo motu disallowance and own funds far exceed investments, the presumption is that investments came from interest-free funds. AJIO marketing and advertisement expenditure was treated as revenue in nature because it comprised recurring business outlays, and accounting treatment alone did not control tax character. CSR-linked donations to an otherwise eligible section 80G institution were held not excluded merely because the spending arose from CSR obligations. Foreign tax credit could not be denied solely for delayed filing of Form 67 where the claim and tax payment details were otherwise available.</description>
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      <description>Section 80JJAA allows deduction for additional employee cost over the statutory three-year period, so a later-year claim is not barred merely because the amount relates to earlier eligible years. Disallowance under section 14A read with Rule 8D requires proper dissatisfaction with the accounts, and where the assessee has made a suo motu disallowance and own funds far exceed investments, the presumption is that investments came from interest-free funds. AJIO marketing and advertisement expenditure was treated as revenue in nature because it comprised recurring business outlays, and accounting treatment alone did not control tax character. CSR-linked donations to an otherwise eligible section 80G institution were held not excluded merely because the spending arose from CSR obligations. Foreign tax credit could not be denied solely for delayed filing of Form 67 where the claim and tax payment details were otherwise available.</description>
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