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    <description>Interest attributable to trade advances used as business funding was held not disallowable merely because the advances financed construction of a factory building, once the asset had been put to use and no diversion for non-business purposes was shown. The reimbursement of salaries and allowances for deputed employees was not finally decided on the existing record, because the true character of the secondment arrangement and the services actually rendered had not been examined in detail; the matter was therefore sent back for fresh factual inquiry on whether the payments were mere reimbursement or taxable amounts subject to withholding tax.</description>
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