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    <title>2026 (7) TMI 1400 - ITAT JAIPUR</title>
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    <description>Related-party interest may be disallowed under Section 40A(2)(b) only to the extent it exceeds fair market value; absent a finding of excessiveness, separate loan and trade-current accounts cannot be consolidated to impute notional interest income. The interest-related disallowance and addition were deleted. Delayed employees&#039; PF/ESI contributions were disallowed under the binding Checkmate Services position. Software services and maintenance expenditure was disallowed because the supporting bill and other evidence did not establish the nature or genuineness of the services. Brokerage paid to a related party for unsecured loans was also disallowed because it was disproportionate and unsupported by evidence of its basis or genuineness.</description>
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      <link>https://www.taxtmi.com/caselaws?id=795514</link>
      <description>Related-party interest may be disallowed under Section 40A(2)(b) only to the extent it exceeds fair market value; absent a finding of excessiveness, separate loan and trade-current accounts cannot be consolidated to impute notional interest income. The interest-related disallowance and addition were deleted. Delayed employees&#039; PF/ESI contributions were disallowed under the binding Checkmate Services position. Software services and maintenance expenditure was disallowed because the supporting bill and other evidence did not establish the nature or genuineness of the services. Brokerage paid to a related party for unsecured loans was also disallowed because it was disproportionate and unsupported by evidence of its basis or genuineness.</description>
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