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    <title>2026 (5) TMI 1692 - ITAT PUNE</title>
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    <description>Rule 8D&#039;s amended disallowance mechanism was treated as prospective, so the pre-amendment method applied to assessment year 2016-17 and the section 14A computation for assessment year 2017-18 was confined to investments yielding exempt income. Disallowance under section 14A read with Rule 8D was held not to enter book-profit computation under section 115JB, so no MAT adjustment was permitted. A provision for bad and doubtful debts was treated as an actual write-off where the corresponding debtor balance was reduced in the accounts, supporting deduction under section 36(1)(vii). An additional ground under section 40(a)(ia) was restored for fresh adjudication.</description>
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      <link>https://www.taxtmi.com/caselaws?id=792489</link>
      <description>Rule 8D&#039;s amended disallowance mechanism was treated as prospective, so the pre-amendment method applied to assessment year 2016-17 and the section 14A computation for assessment year 2017-18 was confined to investments yielding exempt income. Disallowance under section 14A read with Rule 8D was held not to enter book-profit computation under section 115JB, so no MAT adjustment was permitted. A provision for bad and doubtful debts was treated as an actual write-off where the corresponding debtor balance was reduced in the accounts, supporting deduction under section 36(1)(vii). An additional ground under section 40(a)(ia) was restored for fresh adjudication.</description>
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