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of TDS disallowance for professional fees paid to non-residents without TDS deduction was deleted as the payees did not have a fixed base or permanent establishment in India. Disallowance for payments to non-residents for services rendered outside India like VAT compliance, segregation charges for warehousing and delivery, advertisement expenses was deleted as the services did not constitute technical services and the non-residents had no permanent establishment in India. Expenditure towards corporate social responsibility was held allowable as revenue expenditure for the relevant years. Disallowance of interest on interest-free advances to a foundation was remitted back for verification of availability of interest-free funds. Disallowance u/s 80G was remitted back for verification of the donation certificate. Disallowance for market research expenses paid to a US entity was deleted as it did not constitute fees for technical services under the India-US tax treaty.
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