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    <title>2021 (3) TMI 1192 - ITAT MUMBAI</title>
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    <description>Disallowances under section 40(a)(ia) were partly sustained and partly deleted where remand material showed tax deduction compliance, non-deductibility in some cases, or unsupported only for a limited portion of legal and professional fees. BMC and SRA project expenses were deleted because the records substantiated actual payment and the SRA items were already embedded in closing work-in-progress, avoiding double addition. Penalty under section 271(1)(c) was removed because deleted quantum additions could not support penalty and the remaining items did not establish concealment or inaccurate particulars. Additions based on impounded loose papers, alleged partner cash payments, a brokerage note, and net profit differences were deleted as uncorroborated or satisfactorily explained in remand.</description>
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      <description>Disallowances under section 40(a)(ia) were partly sustained and partly deleted where remand material showed tax deduction compliance, non-deductibility in some cases, or unsupported only for a limited portion of legal and professional fees. BMC and SRA project expenses were deleted because the records substantiated actual payment and the SRA items were already embedded in closing work-in-progress, avoiding double addition. Penalty under section 271(1)(c) was removed because deleted quantum additions could not support penalty and the remaining items did not establish concealment or inaccurate particulars. Additions based on impounded loose papers, alleged partner cash payments, a brokerage note, and net profit differences were deleted as uncorroborated or satisfactorily explained in remand.</description>
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