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    <title>2026 (4) TMI 1626 - ITAT AHMEDABAD</title>
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    <description>Interest on fixed deposits, third-party deposits and income-tax refund accrued to the society itself and was not diverted at source by overriding title, because the funds remained under its control and the obligations reflected only later application of income. The receipts were therefore taxable as income from other sources. Expenditure claimed under section 57 was disallowed because the maintenance and administrative costs were not shown to have a direct and exclusive nexus with earning the interest income. Deduction under section 80P(2)(d) was not to be denied merely because the return was filed belatedly under section 139(4) instead of section 139(1), and the claim was directed to be considered after hearing.</description>
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      <link>https://www.taxtmi.com/caselaws?id=790557</link>
      <description>Interest on fixed deposits, third-party deposits and income-tax refund accrued to the society itself and was not diverted at source by overriding title, because the funds remained under its control and the obligations reflected only later application of income. The receipts were therefore taxable as income from other sources. Expenditure claimed under section 57 was disallowed because the maintenance and administrative costs were not shown to have a direct and exclusive nexus with earning the interest income. Deduction under section 80P(2)(d) was not to be denied merely because the return was filed belatedly under section 139(4) instead of section 139(1), and the claim was directed to be considered after hearing.</description>
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