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    <title>2025 (2) TMI 976 - ITAT MUMBAI</title>
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    <description>The ITAT Mumbai dismissed the Revenue&#039;s appeal on three grounds. First, public relation expenses were held allowable as business expenses under section 37, with the AO criticized for not following established precedent. Second, disallowance under section 40(a)(i) for TDS on share services expenses paid to Malaysian entity BASC was reversed, following coordinate bench decisions that such provisions don&#039;t apply to finance, accounting and HR services. Third, product registration expenditure was held revenue in nature, not capital, despite being one-time costs. However, the assessee&#039;s cross-objection regarding dividend distribution tax was dismissed following Special Bench precedent.</description>
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      <description>The ITAT Mumbai dismissed the Revenue&#039;s appeal on three grounds. First, public relation expenses were held allowable as business expenses under section 37, with the AO criticized for not following established precedent. Second, disallowance under section 40(a)(i) for TDS on share services expenses paid to Malaysian entity BASC was reversed, following coordinate bench decisions that such provisions don&#039;t apply to finance, accounting and HR services. Third, product registration expenditure was held revenue in nature, not capital, despite being one-time costs. However, the assessee&#039;s cross-objection regarding dividend distribution tax was dismissed following Special Bench precedent.</description>
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