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    <title>2026 (4) TMI 766 - ITAT DELHI</title>
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    <description>Incidental receipts directly linked to loan processing, sanction, administration and disbursement were treated as profits derived from the business of providing long-term finance, so they qualified for deduction under section 36(1)(viii). Loans sanctioned on terms of at least five years did not lose long-term finance character merely because they were prepaid before that period ended, so the deduction remained available. For section 14A read with Rule 8D, only investments that actually yielded exempt income were included in the disallowance base. CSR-linked contributions to an institution registered under section 80G were not barred from deduction merely because they were made under a CSR obligation, so the deduction was allowable.</description>
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      <description>Incidental receipts directly linked to loan processing, sanction, administration and disbursement were treated as profits derived from the business of providing long-term finance, so they qualified for deduction under section 36(1)(viii). Loans sanctioned on terms of at least five years did not lose long-term finance character merely because they were prepaid before that period ended, so the deduction remained available. For section 14A read with Rule 8D, only investments that actually yielded exempt income were included in the disallowance base. CSR-linked contributions to an institution registered under section 80G were not barred from deduction merely because they were made under a CSR obligation, so the deduction was allowable.</description>
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