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    <title>2020 (10) TMI 718 - ITAT DELHI</title>
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    <description>Distributor incentives structured as trade discounts in a principal-to-principal arrangement were treated as non-commission payments, so no tax deduction obligation arose under the commission or technical services provisions and section 40(a)(ia) disallowance could not stand. Trade price protection paid to distributors was accepted as a commercial sales-promotion expenditure incurred wholly and exclusively for business, making disallowance unjustified. Free-of-cost mobile handsets issued in the course of business were treated as business expenditure rather than capital outlay, and the related depreciation disallowance was also not sustained.</description>
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      <description>Distributor incentives structured as trade discounts in a principal-to-principal arrangement were treated as non-commission payments, so no tax deduction obligation arose under the commission or technical services provisions and section 40(a)(ia) disallowance could not stand. Trade price protection paid to distributors was accepted as a commercial sales-promotion expenditure incurred wholly and exclusively for business, making disallowance unjustified. Free-of-cost mobile handsets issued in the course of business were treated as business expenditure rather than capital outlay, and the related depreciation disallowance was also not sustained.</description>
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