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    <title>2020 (10) TMI 370 - BOMBAY HIGH COURT</title>
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    <description>The court held that the appellant was not liable to deduct tax at source on the reimbursement of freight charges as they did not have an income element. The disallowance under Section 40(a)(ia) was deemed inapplicable, and the deduction under Section 80IB was not addressed due to the favorable rulings on the first two issues. The appeals were allowed, modifying the impugned orders, with the court emphasizing the interpretation of the CBDT Circular in line with the IT Act and judicial precedents.</description>
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      <description>The court held that the appellant was not liable to deduct tax at source on the reimbursement of freight charges as they did not have an income element. The disallowance under Section 40(a)(ia) was deemed inapplicable, and the deduction under Section 80IB was not addressed due to the favorable rulings on the first two issues. The appeals were allowed, modifying the impugned orders, with the court emphasizing the interpretation of the CBDT Circular in line with the IT Act and judicial precedents.</description>
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