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    <title>2025 (2) TMI 1886 - ITAT CHENNAI</title>
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    <description>Where the assessee&#039;s own interest-free funds exceeded the investments, a proportional interest disallowance under section 14A read with Rule 8D(2)(ii) was held unwarranted because the Revenue did not rebut the presumption that the investments came from such funds. The adjustment to book profit under section 115JB on account of a section 14A disallowance was also found unsustainable, as section 115JB operates as a self-contained computation code and section 14A cannot be mechanically imported into that exercise. The exclusion of investments not yielding exempt income for Rule 8D(2)(iii) was treated as consistent with the settled approach.</description>
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    <pubDate>Wed, 05 Feb 2025 00:00:00 +0530</pubDate>
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      <title>2025 (2) TMI 1886 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=468773</link>
      <description>Where the assessee&#039;s own interest-free funds exceeded the investments, a proportional interest disallowance under section 14A read with Rule 8D(2)(ii) was held unwarranted because the Revenue did not rebut the presumption that the investments came from such funds. The adjustment to book profit under section 115JB on account of a section 14A disallowance was also found unsustainable, as section 115JB operates as a self-contained computation code and section 14A cannot be mechanically imported into that exercise. The exclusion of investments not yielding exempt income for Rule 8D(2)(iii) was treated as consistent with the settled approach.</description>
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      <pubDate>Wed, 05 Feb 2025 00:00:00 +0530</pubDate>
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