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    <title>2025 (7) TMI 2000 - ITAT MUMBAI</title>
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    <description>Rule 6E was read purposively so that reversal of a disallowed UEPR amount is not taxed again merely because the reversal occurs in a later year, avoiding double taxation where the earlier disallowance had already been made. The clarification accepted that the timing of reversal need not be confined to the immediately succeeding year, and relief on this point stood in favour of the assessee. Interest under section 234C was also clarified to be computed on returned income, not assessed income, and the computation was directed accordingly in the assessee&#039;s favour.</description>
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      <title>2025 (7) TMI 2000 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=468023</link>
      <description>Rule 6E was read purposively so that reversal of a disallowed UEPR amount is not taxed again merely because the reversal occurs in a later year, avoiding double taxation where the earlier disallowance had already been made. The clarification accepted that the timing of reversal need not be confined to the immediately succeeding year, and relief on this point stood in favour of the assessee. Interest under section 234C was also clarified to be computed on returned income, not assessed income, and the computation was directed accordingly in the assessee&#039;s favour.</description>
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