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    <title>2025 (2) TMI 1781 - ITAT AGRA</title>
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    <description>Revision under section 263 was held unsustainable where the assessment was not shown to be both erroneous and prejudicial to the Revenue. The interest expenditure claimed under section 57(iii) could not be disallowed when the assessee&#039;s principal receipts and related interest income had already been treated as business income in earlier years and no distinguishing basis was shown. Statutory deductions such as partner remuneration and depreciation also could not be denied merely because income had been estimated at a net profit rate; their allowance retained independent legal force on the facts recorded. The revisionary directions were set aside and the assessment as made by the Assessing Officer was restored.</description>
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    <pubDate>Mon, 03 Feb 2025 00:00:00 +0530</pubDate>
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      <title>2025 (2) TMI 1781 - ITAT AGRA</title>
      <link>https://www.taxtmi.com/caselaws?id=468180</link>
      <description>Revision under section 263 was held unsustainable where the assessment was not shown to be both erroneous and prejudicial to the Revenue. The interest expenditure claimed under section 57(iii) could not be disallowed when the assessee&#039;s principal receipts and related interest income had already been treated as business income in earlier years and no distinguishing basis was shown. Statutory deductions such as partner remuneration and depreciation also could not be denied merely because income had been estimated at a net profit rate; their allowance retained independent legal force on the facts recorded. The revisionary directions were set aside and the assessment as made by the Assessing Officer was restored.</description>
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