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    <title>2026 (4) TMI 811 - ITAT AHMEDABAD</title>
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    <description>Under the amended Rule 8D, disallowance of interest expenditure linked to exempt income required a proper factual examination of fund utilisation; because the record did not conclusively show how borrowed funds were deployed, the interest issue was remitted for fresh verification after hearing the assessee. The proportionate disallowance of common expenses was sustained because the assessee was engaged in investment activity and the expenditure had been apportioned on a pro-rata basis. Stock-in-trade could not be included in the revenue base for that computation, as it is not revenue and its inclusion would distort the disallowance exercise.</description>
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