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    <title>2020 (9) TMI 1100 - ITAT MUMBAI</title>
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    <description>Discounts on sale of set-top boxes, recharge vouchers and related promotional incentives were treated as principal-to-principal sales, not commission or brokerage, so no TDS default arose and the related disallowance was deleted. Year-end expense provisions remained subject to tax deduction at the point of credit or payment, and their later reversal did not remove the TDS obligation, so the disallowance was sustained. Interest disallowance linked to capital work-in-progress failed because substantial own funds were available and no nexus with borrowed funds was shown. Disallowance under the anti-avoidance provision could not be made where no exempt income was earned, so the notional addition was deleted.</description>
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