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    <title>2018 (11) TMI 1109 - ITAT RAJKOT</title>
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    <description>Usance interest on delayed import payments was treated as interest liable to TDS, and the disallowance under section 40(a)(i) was restored because the payment was not accepted as part of purchase price and the doctrine of merger did not displace the earlier High Court view. Commission expenditure was largely accepted as relating to the year under consideration on the basis of confirmations, ledgers and vouchers, so the prior-period addition was deleted except for an unexplained mismatch of Rs. 1,870. Alleged excess stock was accepted as reconciled, supported by the competent authority&#039;s withdrawal of the discrepancy notice, and the related profit estimation was deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=370766</link>
      <description>Usance interest on delayed import payments was treated as interest liable to TDS, and the disallowance under section 40(a)(i) was restored because the payment was not accepted as part of purchase price and the doctrine of merger did not displace the earlier High Court view. Commission expenditure was largely accepted as relating to the year under consideration on the basis of confirmations, ledgers and vouchers, so the prior-period addition was deleted except for an unexplained mismatch of Rs. 1,870. Alleged excess stock was accepted as reconciled, supported by the competent authority&#039;s withdrawal of the discrepancy notice, and the related profit estimation was deleted.</description>
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