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    <description>In a best judgment assessment, the estimated net profit rate was moderated from 5% to 4% on the basis of past results and surrounding business circumstances. Commission paid to foreign agents outside India was held not liable to disallowance under section 40(a)(ia) because the payment had no Indian situs and no TDS obligation was attracted; the disallowance was deleted. Duty drawback separately credited by the assessee was upheld as an independent addition to income because it had not been absorbed in the estimated net profit computation.</description>
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