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    <title>2026 (3) TMI 955 - ITAT SURAT</title>
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    <description>Disallowance of proportionate interest on advances is unsustainable where opening/closing balances, part recoveries and consistent accounting show loans originated from the assessee&#039;s own interest free funds; disallowance under withholding rules is not justified where training reimbursements were internal business expenses without an external withholding character; differences between the return and Form 26AS were reconciled by business adjustments (discounts, notes, prior period adjustments) and supported by books, and cash payments including reimbursements were evidenced, so cash payment based disallowance is unwarranted; no remand was required after reasoned substantive disposal, and the appeal succeeds on all challenged grounds.</description>
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    <pubDate>Mon, 16 Mar 2026 00:00:00 +0530</pubDate>
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      <title>2026 (3) TMI 955 - ITAT SURAT</title>
      <link>https://www.taxtmi.com/caselaws?id=788200</link>
      <description>Disallowance of proportionate interest on advances is unsustainable where opening/closing balances, part recoveries and consistent accounting show loans originated from the assessee&#039;s own interest free funds; disallowance under withholding rules is not justified where training reimbursements were internal business expenses without an external withholding character; differences between the return and Form 26AS were reconciled by business adjustments (discounts, notes, prior period adjustments) and supported by books, and cash payments including reimbursements were evidenced, so cash payment based disallowance is unwarranted; no remand was required after reasoned substantive disposal, and the appeal succeeds on all challenged grounds.</description>
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      <pubDate>Mon, 16 Mar 2026 00:00:00 +0530</pubDate>
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