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    <title>2026 (4) TMI 642 - ITAT GUWAHATI</title>
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    <description>Interest expenditure paid to members of a GPF Trust could not be disallowed in full merely on the asserted absence of nexus between funds received and income earned, where the trust&#039;s funds were sourced from employee subscriptions, invested to generate income, and partly deployed as loans and advances. The issue was treated as covered by the assessee&#039;s own earlier year decision, and the addition was directed to be deleted. The earlier reasoning also noted that the enhancement had been made without proper opportunity, engaging principles of natural justice, which reinforced the unsustainable nature of the disallowance.</description>
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      <description>Interest expenditure paid to members of a GPF Trust could not be disallowed in full merely on the asserted absence of nexus between funds received and income earned, where the trust&#039;s funds were sourced from employee subscriptions, invested to generate income, and partly deployed as loans and advances. The issue was treated as covered by the assessee&#039;s own earlier year decision, and the addition was directed to be deleted. The earlier reasoning also noted that the enhancement had been made without proper opportunity, engaging principles of natural justice, which reinforced the unsustainable nature of the disallowance.</description>
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