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We direct the AO to restrict the 100 per cent disallowance confirmed by the CIT(A) to the extent of 30 per cent only taking into account the actual claim of the assessee in its P&L a/c.

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Section 40(a)(ia) of the Income Tax Act, 1961 — Business Disallowance — AO is directed to restrict the disallowance to the extent of 30percent only taking into account the actual claim of the assessee in its P&L a/c as amendment brought to section 40(a)(ia) by Finance Act,2014 whereby the disallowance is to be restricted to 30percent of the amount of Expenditure claimed had retrospective operation — Om Sri Nilamadhan Buikders P. Ltd. [2020] 203 TTJ (Cuttack) 229

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