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2022 (4) TMI 386 - AT - Income TaxCorrect head of income - interest on margin money, interest on loans to employees, interest on day to day balance with bank in current account, interest on blocked money and interest income on margin money / FDR - business income income from other sources - HELD THAT:- We are of the considered view that since the income under consideration is tax neutral and assessee has not pressed this ground being academic in nature, the same is dismissed. However, this issue is kept open and the decision taken for the year under consideration shall not be treated as precedent for the later years. Disallowance u/s 14A r.w.r. 8D while computing the book profits u/s. 115JB - HELD THAT:- In view of what has been discussed above and by following the order passed by the Tribunal in assessee’s own case for A.Y. 2007-08 [2020 (11) TMI 809 - ITAT MUMBAI] we are of the considered view that when the assessee while computing the income under normal provisions of the Act had made suo moto disallowance which has been upheld by the Tribunal For A.Y. 2009-10 the same has to be adopted even while computing the book profit under section 115JB of the Act. So we direct the AO to restrict the disallowance under section 14A while computing the book profit under section 115JB of the Act. Consequently, additional grounds No.1 & 2 raised by the assessee are decided in favour of the assessee.
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