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    <description>Commission paid to non-resident agents for services rendered outside India was treated as not chargeable to tax in India where there was no permanent establishment or business connection, so tax deduction at source and disallowance under section 40(a)(ia) did not arise. Section 14A could not be applied in the absence of exempt income. Interest relating to borrowings for capital work in progress was not disallowed where the assessee&#039;s allocation was supported by a detailed working and the presumption that all term loans funded the project was unproved. Steam generated by a captive power plant was recognised as power for section 80IA, with profits to be computed on a rational allocation basis.</description>
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