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    <title>2026 (8) TMI 379 - ITAT MUMBAI</title>
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    <description>Interest attributable to admitted bogus accommodation loans is not allowable because the underlying loans are non-genuine and their principal amounts were offered as income. Tax deducted at source from the interest payment is not itself interest expenditure and must be excluded from the disallowance. An estimated addition for commission on accommodation entries requires corroborative evidence of actual payment and quantum; it cannot be based solely on a presumption that commission would have been paid. Accordingly, interest is disallowed subject to exclusion of tax deducted at source, while the commission additions are deleted for all relevant assessment years.</description>
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      <title>2026 (8) TMI 379 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=796506</link>
      <description>Interest attributable to admitted bogus accommodation loans is not allowable because the underlying loans are non-genuine and their principal amounts were offered as income. Tax deducted at source from the interest payment is not itself interest expenditure and must be excluded from the disallowance. An estimated addition for commission on accommodation entries requires corroborative evidence of actual payment and quantum; it cannot be based solely on a presumption that commission would have been paid. Accordingly, interest is disallowed subject to exclusion of tax deducted at source, while the commission additions are deleted for all relevant assessment years.</description>
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