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    <description>Expenditure incurred to secure sponsorship rights was treated as deductible under section 37(1) because it was linked to commercial expediency, a continuing business relationship and the recoupment of unutilised consideration; the disallowance was deleted. An estimated professional fee for promised appearances and promotions was not taxed because the services never materialised and there was no receipt, accrual or real income; the addition was deleted. By contrast, the annual value of a Dubai villa was held taxable in India under the India-UAE treaty framework, with foreign tax credit to be dealt with under law, resulting in a partial allowance of the appeal.</description>
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      <description>Expenditure incurred to secure sponsorship rights was treated as deductible under section 37(1) because it was linked to commercial expediency, a continuing business relationship and the recoupment of unutilised consideration; the disallowance was deleted. An estimated professional fee for promised appearances and promotions was not taxed because the services never materialised and there was no receipt, accrual or real income; the addition was deleted. By contrast, the annual value of a Dubai villa was held taxable in India under the India-UAE treaty framework, with foreign tax credit to be dealt with under law, resulting in a partial allowance of the appeal.</description>
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