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    <title>2012 (8) TMI 371 - ITAT MUMBAI</title>
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    <description>Exclusive head office and NRI solicitation expenses incurred wholly for the Indian branch were deductible under section 37(1) and not restricted by section 44C. Entertainment expenditure was subject to section 37(2) read with article 7(3) of the Indo-US DTAA, but the disallowance had to be made on a reasonable basis, fixed at 50% of total expenditure. Expenditure attributable to exempt interest income on tax-free bonds was disallowable under section 14A on a reasonable basis. Income taxed at a special rate under section 115A was not exempt income, so related expenditure could be claimed against normal taxable income. Club expenses were allowable as a business deduction.</description>
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