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    <title>2026 (6) TMI 1258 - ITAT MUMBAI</title>
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    <description>The article addresses recurring income-tax issues decided in the assessee&#039;s favour on consistency: transfer pricing adjustments on interest to associated enterprises and corporate guarantee fee were upheld on the basis of earlier years and comparable facts; deduction under section 80-IA was allowed for the rail system, water system and CER receipts; relief under section 14A and the corresponding book-profit adjustment under section 115JB was sustained because interest-free funds exceeded investments; and receipts from prepayment of sales tax deferrals were treated as capital, while the project-creditor write-off was not taxed under section 28(iv). The overall approach was to follow prior year and related-group decisions where no material change in facts was shown.</description>
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