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    <title>2026 (7) TMI 47 - ITAT DELHI</title>
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    <description>Interest received on income-tax refund under section 244A was held to have a sufficient commercial and causal nexus with the assessee&#039;s banking business for deduction under section 80P(2)(a)(i). The Tribunal applied the wider meaning of &quot;attributable to&quot;, as distinct from &quot;derived from&quot;, and followed the binding Special Bench view that refund interest arising from tax paid in relation to banking activity retains the requisite business connection. The amount could not be assessed as income from other sources, and the corresponding addition was deleted in favour of the assessee.</description>
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      <description>Interest received on income-tax refund under section 244A was held to have a sufficient commercial and causal nexus with the assessee&#039;s banking business for deduction under section 80P(2)(a)(i). The Tribunal applied the wider meaning of &quot;attributable to&quot;, as distinct from &quot;derived from&quot;, and followed the binding Special Bench view that refund interest arising from tax paid in relation to banking activity retains the requisite business connection. The amount could not be assessed as income from other sources, and the corresponding addition was deleted in favour of the assessee.</description>
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