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    <title>2026 (4) TMI 253 - ITAT AHMEDABAD</title>
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    <description>Disallowance under section 14A read with Rule 8D was found unsustainable where the assessee earned no exempt income during the year and its own funds were substantially higher than the investments. The Assessing Officer also failed to establish any direct nexus between borrowed funds and the investments. In the absence of exempt income and without proof of borrowed-fund deployment, binding jurisdictional High Court precedents required deletion of the disallowance, and the Revenue&#039;s challenge failed.</description>
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      <description>Disallowance under section 14A read with Rule 8D was found unsustainable where the assessee earned no exempt income during the year and its own funds were substantially higher than the investments. The Assessing Officer also failed to establish any direct nexus between borrowed funds and the investments. In the absence of exempt income and without proof of borrowed-fund deployment, binding jurisdictional High Court precedents required deletion of the disallowance, and the Revenue&#039;s challenge failed.</description>
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