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    <title>2022 (1) TMI 1082 - ITAT DELHI</title>
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    <description>AMP expenditure could not be adjusted unless an international transaction was first established on evidence independent of the bright line test; the Tribunal followed the jurisdictional High Court&#039;s view that the alleged excess AMP spend did not constitute such a transaction, while remitting the matter for consequential action. Professional fees were not disallowable for short deduction of tax where tax had in fact been deducted, as the disallowance provision applies to failure to deduct tax in full, not mere short deduction. Advances written off were sustained on binding precedents, and the stamp duty provision was not disallowed because it did not result in a capital asset or enduring benefit.</description>
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      <description>AMP expenditure could not be adjusted unless an international transaction was first established on evidence independent of the bright line test; the Tribunal followed the jurisdictional High Court&#039;s view that the alleged excess AMP spend did not constitute such a transaction, while remitting the matter for consequential action. Professional fees were not disallowable for short deduction of tax where tax had in fact been deducted, as the disallowance provision applies to failure to deduct tax in full, not mere short deduction. Advances written off were sustained on binding precedents, and the stamp duty provision was not disallowed because it did not result in a capital asset or enduring benefit.</description>
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