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    <title>2026 (4) TMI 255 - ITAT MUMBAI</title>
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    <description>Section 14A disallowance was discussed on the basis that sufficient interest-free funds covered the exempt investments, so no interest expenditure was attributable to exempt income and the administrative disallowance was confined consistently to 2% of exempt income. Professional fees for strategic planning, public relations and business support were treated as revenue expenditure because they did not create an enduring capital asset. Bad debts written off were stated to be allowable once written off in the accounts and earlier taxed, without proof of actual irrecoverability. Deduction under section 80IA for captive incinerator services was accepted where the facility formed part of hazardous-waste management and market value could be determined. Levy of interest under section 234A was said to depend on verification of timely return filing.</description>
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      <link>https://www.taxtmi.com/caselaws?id=789186</link>
      <description>Section 14A disallowance was discussed on the basis that sufficient interest-free funds covered the exempt investments, so no interest expenditure was attributable to exempt income and the administrative disallowance was confined consistently to 2% of exempt income. Professional fees for strategic planning, public relations and business support were treated as revenue expenditure because they did not create an enduring capital asset. Bad debts written off were stated to be allowable once written off in the accounts and earlier taxed, without proof of actual irrecoverability. Deduction under section 80IA for captive incinerator services was accepted where the facility formed part of hazardous-waste management and market value could be determined. Levy of interest under section 234A was said to depend on verification of timely return filing.</description>
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