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    <title>2019 (11) TMI 982 - ITAT MUMBAI</title>
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    <description>The Tribunal dismissed the Revenue&#039;s appeal, upholding the decision of the Commission (Appeals) to delete the disallowance under Section 41(1) of the Income Tax Act for the assessment year in question. The Tribunal found that the liability did not cease to exist merely because it remained outstanding for over three years, as the amount was eventually repaid after obtaining necessary approvals, indicating no remission or cessation of liability as required by the Act. Additionally, the Tribunal rejected the Revenue&#039;s claim of Rule 46A violation, stating that the Commission (Appeals) had appropriately considered all relevant facts and materials before making the decision.</description>
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      <title>2019 (11) TMI 982 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=388733</link>
      <description>The Tribunal dismissed the Revenue&#039;s appeal, upholding the decision of the Commission (Appeals) to delete the disallowance under Section 41(1) of the Income Tax Act for the assessment year in question. The Tribunal found that the liability did not cease to exist merely because it remained outstanding for over three years, as the amount was eventually repaid after obtaining necessary approvals, indicating no remission or cessation of liability as required by the Act. Additionally, the Tribunal rejected the Revenue&#039;s claim of Rule 46A violation, stating that the Commission (Appeals) had appropriately considered all relevant facts and materials before making the decision.</description>
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