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    <title>2016 (8) TMI 419 - ITAT VISAKHAPATNAM</title>
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    <description>Subscription charges paid to pay channels were treated as a direct business cost incurred to earn subscription revenue and, therefore, as part of commercial profit computation under section 28(1). On that basis, the payment was not regarded as a deduction claimed under sections 30 to 38, so the disallowance mechanism in section 40(a)(ia) for non-deduction of tax at source did not apply. The factual finding that the expenditure fell outside the specific disallowance provision was not displaced, and the addition was deleted in favour of the assessee.</description>
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      <description>Subscription charges paid to pay channels were treated as a direct business cost incurred to earn subscription revenue and, therefore, as part of commercial profit computation under section 28(1). On that basis, the payment was not regarded as a deduction claimed under sections 30 to 38, so the disallowance mechanism in section 40(a)(ia) for non-deduction of tax at source did not apply. The factual finding that the expenditure fell outside the specific disallowance provision was not displaced, and the addition was deleted in favour of the assessee.</description>
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