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    <title>2023 (10) TMI 1009 - ITAT DELHI</title>
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    <description>ITAT Delhi dismissed Revenue&#039;s appeal across multiple disallowances. Regarding excessive expenses under section 40A(2)(b), AO incorrectly treated reimbursements as support services when actual expenses were allocated per cost allocation policy with proper TDS deduction. For rental expenditure, AO used old rent agreement instead of revised agreement showing reduced premises after art gallery closure. CENVAT credit write-off was properly certified by statutory auditors and allowable under section 37(1). Finance cost disallowance of 50% was unjustified as borrowed funds never exceeded working capital requirements and no diversion from business purposes was established. CIT(A)&#039;s deletions were upheld in all matters.</description>
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    <pubDate>Wed, 09 Aug 2023 00:00:00 +0530</pubDate>
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      <title>2023 (10) TMI 1009 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=444786</link>
      <description>ITAT Delhi dismissed Revenue&#039;s appeal across multiple disallowances. Regarding excessive expenses under section 40A(2)(b), AO incorrectly treated reimbursements as support services when actual expenses were allocated per cost allocation policy with proper TDS deduction. For rental expenditure, AO used old rent agreement instead of revised agreement showing reduced premises after art gallery closure. CENVAT credit write-off was properly certified by statutory auditors and allowable under section 37(1). Finance cost disallowance of 50% was unjustified as borrowed funds never exceeded working capital requirements and no diversion from business purposes was established. CIT(A)&#039;s deletions were upheld in all matters.</description>
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