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    <title>2012 (6) TMI 325 - ITAT MUMBAI</title>
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    <description>Verified pre-operative expenditure supported by books, bills and vouchers could not be treated as unexplained expenditure under section 69C where the source was explained through share capital and share application money and the Assessing Officer found no evidence that the spending was bogus or personal. Section 69C applies only when the expenditure itself remains unexplained, not merely because its business necessity is questioned. Reimbursement-based pre-commencement payments at actuals, with no profit element shown, were also held not liable to disallowance under sections 40(a)(ia) or 40A(3) on these facts, so the addition and disallowance were deleted.</description>
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    <pubDate>Wed, 02 May 2012 00:00:00 +0530</pubDate>
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      <title>2012 (6) TMI 325 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=214005</link>
      <description>Verified pre-operative expenditure supported by books, bills and vouchers could not be treated as unexplained expenditure under section 69C where the source was explained through share capital and share application money and the Assessing Officer found no evidence that the spending was bogus or personal. Section 69C applies only when the expenditure itself remains unexplained, not merely because its business necessity is questioned. Reimbursement-based pre-commencement payments at actuals, with no profit element shown, were also held not liable to disallowance under sections 40(a)(ia) or 40A(3) on these facts, so the addition and disallowance were deleted.</description>
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