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    <title>2022 (4) TMI 581 - ITAT AHMEDABAD</title>
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    <description>Payment for pre-existing designs to a non-resident required closer factual examination before disallowance under section 40(a)(i), because the record did not clearly establish that the payment was for technical or included services; the matter was therefore remitted for fresh adjudication. Employees&#039; provident fund contribution deposited beyond the statutory due date remained disallowable under the binding time-limit rule in section 36(1)(va) read with section 2(24)(x), so the disallowance was sustained. Scholarship expenditure claimed for a related person was not shown to have a real business nexus or commercial expediency under section 37, and that disallowance was also upheld.</description>
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      <description>Payment for pre-existing designs to a non-resident required closer factual examination before disallowance under section 40(a)(i), because the record did not clearly establish that the payment was for technical or included services; the matter was therefore remitted for fresh adjudication. Employees&#039; provident fund contribution deposited beyond the statutory due date remained disallowable under the binding time-limit rule in section 36(1)(va) read with section 2(24)(x), so the disallowance was sustained. Scholarship expenditure claimed for a related person was not shown to have a real business nexus or commercial expediency under section 37, and that disallowance was also upheld.</description>
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