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    <title>2022 (6) TMI 1556 - ITAT PUNE</title>
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    <description>Interest disallowance under section 36(1)(iii) was not sustained where the assessee had sufficient interest-free funds and the advances to sister concerns arose from opening balances, creating a presumption that the advances were made from non-borrowed funds. Deduction under section 80-IA was also upheld because the same claim had been accepted in earlier years, the initial assessment year was treated as the year of first claim, and losses or depreciation of prior years already absorbed were not to be notionally carried forward again to reduce the deduction. The Revenue&#039;s appeals therefore failed on both issues.</description>
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    <pubDate>Wed, 08 Jun 2022 00:00:00 +0530</pubDate>
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      <title>2022 (6) TMI 1556 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=467687</link>
      <description>Interest disallowance under section 36(1)(iii) was not sustained where the assessee had sufficient interest-free funds and the advances to sister concerns arose from opening balances, creating a presumption that the advances were made from non-borrowed funds. Deduction under section 80-IA was also upheld because the same claim had been accepted in earlier years, the initial assessment year was treated as the year of first claim, and losses or depreciation of prior years already absorbed were not to be notionally carried forward again to reduce the deduction. The Revenue&#039;s appeals therefore failed on both issues.</description>
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      <pubDate>Wed, 08 Jun 2022 00:00:00 +0530</pubDate>
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