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    <title>2015 (11) TMI 1745 - ITAT MUMBAI</title>
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    <description>Section 14A read with Rule 8D disallowance was unsustainable because the Assessing Officer had not first recorded dissatisfaction with the assessee&#039;s own expenditure computation, so the addition was deleted. Gift article expenditure and closing stock valuation were not disturbed, as the Tribunal followed its earlier orders in the assessee&#039;s own case. The transfer pricing adjustment on guarantee commission from the associated enterprise was also deleted on the basis of earlier co-ordinate bench rulings. Depreciation on advertisement expenditure was denied because the same outlay had already been allowed as revenue expenditure. The additional ground on royalty income under the India-Egypt DTAA was admitted, but the issue was remitted to the Assessing Officer for fresh consideration.</description>
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      <description>Section 14A read with Rule 8D disallowance was unsustainable because the Assessing Officer had not first recorded dissatisfaction with the assessee&#039;s own expenditure computation, so the addition was deleted. Gift article expenditure and closing stock valuation were not disturbed, as the Tribunal followed its earlier orders in the assessee&#039;s own case. The transfer pricing adjustment on guarantee commission from the associated enterprise was also deleted on the basis of earlier co-ordinate bench rulings. Depreciation on advertisement expenditure was denied because the same outlay had already been allowed as revenue expenditure. The additional ground on royalty income under the India-Egypt DTAA was admitted, but the issue was remitted to the Assessing Officer for fresh consideration.</description>
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