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    <title>2008 (4) TMI 356 - ITAT DELHI-F</title>
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    <description>Commission to intermediaries was disallowed because the assessee produced only sale bills and payment entries, with no agreement or evidence of specific services, so the section 37 business-expenditure test was not met. Entertainment expenses were partly treated as business expenditure, but the employee-related allocation lacked sufficient record and was remanded to the Assessing Officer for fresh examination. The pre-2002 section 92 transfer-pricing adjustment was deleted because mere suspicion or lower profits did not establish the required resident-non-resident arrangement producing no or less than ordinary profit. Foreign exchange forward loss and commission to M/s Meemar were allowed on the basis of an ascertained liability and supporting contract and sales documents.</description>
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      <title>2008 (4) TMI 356 - ITAT DELHI-F</title>
      <link>https://www.taxtmi.com/caselaws?id=65415</link>
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