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    <title>2026 (7) TMI 1212 - ITAT MUMBAI</title>
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    <description>Interest disallowance under section 14A read with Rule 8D(2)(ii) was not warranted where interest-free own funds exceeded investments. Administrative expenses under Rule 8D(2)(iii) were directed to be recomputed using only investments that yielded exempt income. Deduction under section 80IC could not be restricted solely because the eligible unit had higher profitability, absent defects, artificial profit inflation, non-market inter-unit transfers, or improper allocation. For the pre-amendment period, Form 3CL did not statutorily quantify eligible in-house R&amp;D expenditure under section 35(2AB). Mark-to-market loss on forward contracts hedging export receivables was treated as an allowable business deduction. AIR/TDS income additions required fresh examination of the reconciliation and supporting evidence.</description>
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      <link>https://www.taxtmi.com/caselaws?id=795326</link>
      <description>Interest disallowance under section 14A read with Rule 8D(2)(ii) was not warranted where interest-free own funds exceeded investments. Administrative expenses under Rule 8D(2)(iii) were directed to be recomputed using only investments that yielded exempt income. Deduction under section 80IC could not be restricted solely because the eligible unit had higher profitability, absent defects, artificial profit inflation, non-market inter-unit transfers, or improper allocation. For the pre-amendment period, Form 3CL did not statutorily quantify eligible in-house R&amp;D expenditure under section 35(2AB). Mark-to-market loss on forward contracts hedging export receivables was treated as an allowable business deduction. AIR/TDS income additions required fresh examination of the reconciliation and supporting evidence.</description>
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