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    <title>2026 (5) TMI 1781 - ITAT MUMBAI</title>
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    <description>Actual rent under registered and genuine commercial lease arrangements could not be substituted by notional market rent under section 23(1)(a) in the absence of evidence of suppression, sham, or colourable bifurcation of receipts, so the enhancement of annual letting value was unsustainable. Interest on borrowings used to acquire commercial property was allowable under section 24(b) where the borrowings were linked to the acquisition and no diversion was shown, so the disallowance failed. Section 14A read with Rule 8D could not be applied where no exempt income accrued during the relevant years, and the Finance Act, 2022 Explanation was treated as prospective, so the disallowance was deleted.</description>
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      <description>Actual rent under registered and genuine commercial lease arrangements could not be substituted by notional market rent under section 23(1)(a) in the absence of evidence of suppression, sham, or colourable bifurcation of receipts, so the enhancement of annual letting value was unsustainable. Interest on borrowings used to acquire commercial property was allowable under section 24(b) where the borrowings were linked to the acquisition and no diversion was shown, so the disallowance failed. Section 14A read with Rule 8D could not be applied where no exempt income accrued during the relevant years, and the Finance Act, 2022 Explanation was treated as prospective, so the disallowance was deleted.</description>
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