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    <title>2021 (10) TMI 162 - ITAT DELHI</title>
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    <description>Bank guarantee commission paid to scheduled banks was treated as a banking service charge, not commission for TDS disallowance under section 40(a)(ia). Notional interest on unrecovered advances was held not taxable as real income, and related interest additions on deposits were also rejected. Demurrage and wharfage charges were treated as compensatory business , while write-off of slow-moving stores and spares was accepted as a bona fide valuation exercise. Section 14A was held inapplicable where no exempt income arose. UPS qualified as a computer peripheral for higher depreciation, ad hoc repair and maintenance disallowances were unsustainable, and CSR expenditure was not hit by section 37(1) for the relevant year because Explanation 2 applies prospectively.</description>
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      <link>https://www.taxtmi.com/caselaws?id=413110</link>
      <description>Bank guarantee commission paid to scheduled banks was treated as a banking service charge, not commission for TDS disallowance under section 40(a)(ia). Notional interest on unrecovered advances was held not taxable as real income, and related interest additions on deposits were also rejected. Demurrage and wharfage charges were treated as compensatory business , while write-off of slow-moving stores and spares was accepted as a bona fide valuation exercise. Section 14A was held inapplicable where no exempt income arose. UPS qualified as a computer peripheral for higher depreciation, ad hoc repair and maintenance disallowances were unsustainable, and CSR expenditure was not hit by section 37(1) for the relevant year because Explanation 2 applies prospectively.</description>
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