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    <title>2026 (5) TMI 1318 - ITAT LUCKNOW</title>
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    <description>Disallowance under section 14A read with Rule 8D was justified where the assessee failed to substantiate its claim of nominal expenditure relatable to exempt income, and the record showed rejection of that claim on the basis that investment activity necessarily uses common resources and managerial inputs. The computation, however, had to be confined to the average value of investments that actually yielded exempt income, because using the entire investment base was erroneous. The principle was sustained in substance, but the disallowance required recomputation on the correct exempt-income yielding investments base.</description>
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      <description>Disallowance under section 14A read with Rule 8D was justified where the assessee failed to substantiate its claim of nominal expenditure relatable to exempt income, and the record showed rejection of that claim on the basis that investment activity necessarily uses common resources and managerial inputs. The computation, however, had to be confined to the average value of investments that actually yielded exempt income, because using the entire investment base was erroneous. The principle was sustained in substance, but the disallowance required recomputation on the correct exempt-income yielding investments base.</description>
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