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    <title>2017 (9) TMI 105 - ITAT KOLKATA</title>
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    <description>Retail discounts on SIM cards and recharge coupons were treated as a sale discount, not commission, because the difference from MRP was not debited as expenditure or claimed in computing business income. Section 40(a)(ia) applies only where the amount is of a deductible nature, tax is required to be deducted on it, and the sum has been claimed as a deduction. Since no deduction was claimed, no disallowance could be made, and the addition was deleted. The principal-agent issue and reliance on jurisdictional precedent became unnecessary to decide.</description>
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