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    <description>Discount extended to prepaid distributors was treated as falling outside commission treatment under section 194H, so the related disallowance under section 40(a)(ia) was deleted. Year-end accruals reversed in the next financial year were treated as accounting provisions where no identifiable payee had earned income on the mere entry, so no disallowance under section 40(a)(ia) was sustained. Club entrance fee and subscription charges were treated as business expenditure in revenue character, not capital expenditure, and the corresponding disallowance was deleted. The overall result was that all substantive additions were removed.</description>
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