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2022 (9) TMI 866 - AT - Income TaxDisallowance u/s 14A r.w.r. 8D - Expenditure incurred on earning exempt income - HELD THAT:- In absence of any contrary material on record, we do not see any infirmity in the said findings of the CIT(A) who has followed the decisions of the Hon'ble High Court and Hon'ble Supreme Court in upholding the applicability of disallowance and restricting the same to the extent of exempt income. The ground taken by the assessee is accordingly dismissed. Disallowance u/s. 36(1)(viia) on account of provision of NPA written back - HELD THAT:- After hearing the DR and pursuing the material available on record, we do not see any infirmity in the findings of the CIT(A) where a consistent position has been adopted by the CIT(A) and nothing has been brought on record to contest the said findings for the earlier years and for the year under consideration. Hence, the findings of the CIT(A) are hereby confirmed and the ground of appeal is dismissed. Addition on account of interest on seed money - HELD THAT:- Assessee was entitled to collect and recover the seed money from entrepreneurs during the course of its business and therefore, the interest income on such seed money accrued to the assessee on its own right. It has been further held by CIT(A) that besides retaining the seed money, the assessee, the interest accruing on the seed money has been retained by the assessee and nothing has been brought on record to demonstrate the transfer of this amount to the State Government. CIT(A) observed that where any amount has actually paid by the assessee to the State Government that would be allowed as expenditure in the year it is actually paid and give that no amount has been paid by the assessee during the year, the AO was fully justified in adding interest received on seed money - we do not see any infirmity in the findings of the ld. CIT(A) and the same is hereby confirmed and ground of appeal taken by the assessee is dismissed.
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