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    <title>2024 (3) TMI 658 - ITAT MUMBAI</title>
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    <description>Section 14A read with Rule 8D requires recorded dissatisfaction before disallowance is made; absent such satisfaction, the disallowance is deleted. Expenditure on business opportunity evaluation, prior period items, and sundry balances written off required item-wise factual verification and was remitted. Mere provision for doubtful debts was not deductible without an actual write-off. Colour Idea Stores expenditure, trip scheme expenditure, balance additional depreciation carried forward, and weighted deduction under section 35(2AB) were treated as allowable on the facts and consistent precedent. Waiver of royalty in favour of foreign subsidiaries was not taxed as notional income, and subsidy and electricity grant receipts were held to be capital receipts under the purpose test.</description>
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      <link>https://www.taxtmi.com/caselaws?id=450877</link>
      <description>Section 14A read with Rule 8D requires recorded dissatisfaction before disallowance is made; absent such satisfaction, the disallowance is deleted. Expenditure on business opportunity evaluation, prior period items, and sundry balances written off required item-wise factual verification and was remitted. Mere provision for doubtful debts was not deductible without an actual write-off. Colour Idea Stores expenditure, trip scheme expenditure, balance additional depreciation carried forward, and weighted deduction under section 35(2AB) were treated as allowable on the facts and consistent precedent. Waiver of royalty in favour of foreign subsidiaries was not taxed as notional income, and subsidy and electricity grant receipts were held to be capital receipts under the purpose test.</description>
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