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    <title>2021 (9) TMI 600 - ITAT CHENNAI</title>
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    <description>Statutory transfer to a reserve fund under section 45IC of the RBI Act was treated as an appropriation of profits, so it was not deductible in computing business income and was also not excludable while determining book profit under section 115JB. A disallowance under section 14A was not sustainable where no exempt income was earned during the year, so that addition was deleted. Royalty paid for use of a logo was treated as revenue expenditure because it only secured a right to use the mark and did not create an enduring asset, so it was allowable. Commission expenditure was partly outside section 194H where individual payments did not cross the threshold, but disallowance under section 40(a)(ia) survived for the balance where tax was not deducted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=412255</link>
      <description>Statutory transfer to a reserve fund under section 45IC of the RBI Act was treated as an appropriation of profits, so it was not deductible in computing business income and was also not excludable while determining book profit under section 115JB. A disallowance under section 14A was not sustainable where no exempt income was earned during the year, so that addition was deleted. Royalty paid for use of a logo was treated as revenue expenditure because it only secured a right to use the mark and did not create an enduring asset, so it was allowable. Commission expenditure was partly outside section 194H where individual payments did not cross the threshold, but disallowance under section 40(a)(ia) survived for the balance where tax was not deducted.</description>
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