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    <title>2026 (7) TMI 121 - ITAT AHMEDABAD</title>
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    <description>Management fee paid to a related entity was held not to warrant disallowance under section 40A(2)(b) because the facts matched earlier years, where the payment had been accepted as revenue in nature for operational and management rights, and no fresh distinguishing circumstance was shown. The section 14A disallowance was confined to the amount of exempt income, reflecting the settled principle that such disallowance cannot exceed the exempt income earned and the consistent treatment followed in the assessee&#039;s own earlier years. The first appellate relief was sustained on both substantive issues, and the cross-objection did not survive.</description>
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      <description>Management fee paid to a related entity was held not to warrant disallowance under section 40A(2)(b) because the facts matched earlier years, where the payment had been accepted as revenue in nature for operational and management rights, and no fresh distinguishing circumstance was shown. The section 14A disallowance was confined to the amount of exempt income, reflecting the settled principle that such disallowance cannot exceed the exempt income earned and the consistent treatment followed in the assessee&#039;s own earlier years. The first appellate relief was sustained on both substantive issues, and the cross-objection did not survive.</description>
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