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80HHC

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(Querist)
28 April 2009 Can Net Interest income be taken as consideration for computing deduction u/s 80HHC ??
Is business nexus between interest received & paid a prerequisite condition for netting of interest??
please quote relevent case law for the same, if any.
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Bhaskaran Chackrapani Warrier

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Bhaskaran Chackrapani Warrier (Expert)
28 April 2009 Netting of interest is not allowed in CIT Vs.V.Chinnapandi (2006)282ITR 389(Mad). Here the assssee paid interest Rs.9.25lakhs and received interest Rs.2.65lakhs. The A.O treated gross receipts as miscellaneous income and excluded 90% of the same for 80HHC calculation. The H.C upheld the A.O's decision and ignored the interest payment from eligible profits.
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