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    <title>2024 (1) TMI 157 - ITAT DELHI</title>
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    <description>ITAT DELHI - AT allowed the appeal in major respects. Disallowance of overseas commission expenses was set aside: payments to foreign agents for securing orders outside India are not taxable here and s.195 TDS was not required. Excess disallowance under s.14A (r.w. Rule 8D) was deleted, limiting any disallowance to investments that generated tax-free income. ESOP-related expenses were held revenue and allowable. Additions treating purchases as bogus were reversed and restored to the assessee&#039;s accounts. Transfer-pricing adjustment for standby L/C commission was deleted for lack of cost borne by the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=447758</link>
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