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    <description>Royalty paid to an associated enterprise was not disallowable where it was supported by invoices, agreements and banking records, and the transfer pricing authority had already accepted the transaction at arm&#039;s length; absent material showing lack of genuineness, conjecture could not justify adjustment. Separately, section 40(a)(i) denied deduction for the year under appeal where tax deductible on royalty was deducted and deposited only later, but the proviso allowed the expenditure in the year in which the tax was actually paid. The royalty addition on merits was deleted, while the year-wise disallowance under section 40(a)(i) was confined to the year of default.</description>
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