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    <title>1991 (2) TMI 171 - ITAT ALLAHABAD-A</title>
    <link>https://www.taxtmi.com/caselaws?id=56798</link>
    <description>Interest under sections 139(8), 217 and 215 was held inapplicable to a reassessment under section 147 because &quot;regular assessment&quot; refers only to assessments under sections 143 or 144; the levy was therefore not sustainable. Notional interest on an old advance could not be disallowed without evidence that interest had actually accrued or been charged, so that disallowance failed. Interest payable outside India was disallowed under section 40(a)(i) where the assessee did not show that tax had been paid or deducted, so the Revenue succeeded on that point. Deduction under section 80L could not exceed the statutory ceiling, and the higher allowance was reduced to the prescribed limit.</description>
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    <pubDate>Thu, 07 Feb 1991 00:00:00 +0530</pubDate>
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      <title>1991 (2) TMI 171 - ITAT ALLAHABAD-A</title>
      <link>https://www.taxtmi.com/caselaws?id=56798</link>
      <description>Interest under sections 139(8), 217 and 215 was held inapplicable to a reassessment under section 147 because &quot;regular assessment&quot; refers only to assessments under sections 143 or 144; the levy was therefore not sustainable. Notional interest on an old advance could not be disallowed without evidence that interest had actually accrued or been charged, so that disallowance failed. Interest payable outside India was disallowed under section 40(a)(i) where the assessee did not show that tax had been paid or deducted, so the Revenue succeeded on that point. Deduction under section 80L could not exceed the statutory ceiling, and the higher allowance was reduced to the prescribed limit.</description>
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      <pubDate>Thu, 07 Feb 1991 00:00:00 +0530</pubDate>
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