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    <title>2012 (10) TMI 609 - ITAT AHMEDABAD</title>
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    <description>Commission paid to sales agents is generally allowable under section 37 when supported by agreements and evidence of services, with disallowance confined to isolated transactions where the agents had no role. Section 14A interest disallowance does not apply where foreign-subsidiary dividends are taxable and no nexus is shown between borrowed funds and investments; proportionate administrative disallowance may still apply for exempt income from Indian subsidiaries. Interest on fixed deposits and inter-corporate deposits is not derived from the undertaking for section 80-IB, though only net interest may be excluded in computation. Duty drawback linked to duty-paid inputs, employees&#039; PF/ESI paid before the return due date, and survey disclosure unsupported by incriminating material were treated as allowable or unsustained.</description>
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    <pubDate>Fri, 21 Sep 2012 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=217671</link>
      <description>Commission paid to sales agents is generally allowable under section 37 when supported by agreements and evidence of services, with disallowance confined to isolated transactions where the agents had no role. Section 14A interest disallowance does not apply where foreign-subsidiary dividends are taxable and no nexus is shown between borrowed funds and investments; proportionate administrative disallowance may still apply for exempt income from Indian subsidiaries. Interest on fixed deposits and inter-corporate deposits is not derived from the undertaking for section 80-IB, though only net interest may be excluded in computation. Duty drawback linked to duty-paid inputs, employees&#039; PF/ESI paid before the return due date, and survey disclosure unsupported by incriminating material were treated as allowable or unsustained.</description>
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