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    <title>2026 (3) TMI 1474 - ITAT MUMBAI</title>
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    <description>Where interest-free funds were sufficient to cover investments, the presumption that they were sourced from such funds was applied, so proportionate interest disallowance under rule 8D(2)(ii) was deleted; the restricted administrative disallowance under rule 8D(2)(iii) was sustained. On advances to a group concern, notional interest under section 36(1)(iii) was not disallowable because the advances were from earlier years, no fresh advance was made during the year, repayment was received, and own funds exceeded the advances. Expenditure for specialised scientific research reports was held to be allowable as business deduction, even though the weighted-deduction claim failed for want of approval.</description>
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    <pubDate>Thu, 12 Mar 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=788719</link>
      <description>Where interest-free funds were sufficient to cover investments, the presumption that they were sourced from such funds was applied, so proportionate interest disallowance under rule 8D(2)(ii) was deleted; the restricted administrative disallowance under rule 8D(2)(iii) was sustained. On advances to a group concern, notional interest under section 36(1)(iii) was not disallowable because the advances were from earlier years, no fresh advance was made during the year, repayment was received, and own funds exceeded the advances. Expenditure for specialised scientific research reports was held to be allowable as business deduction, even though the weighted-deduction claim failed for want of approval.</description>
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