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    <title>2025 (4) TMI 905 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai decided multiple issues for an insurance company. Foreign dividend income must be offered on gross basis, not net after TDS deduction, following previous adverse ruling. Payments to auto dealers were allowed as genuine outsourced activity expenses per IRDA guidelines, rejecting revenue&#039;s claim these were disguised commissions based on reversed Central Excise findings. Profit on investment sale remained exempt under section 10(38) following Bombay HC precedent. Section 14A disallowance was deleted as inapplicable to insurance companies governed by section 44. Amortization of premium on securities was allowed as revenue expenditure. Revenue&#039;s appeal regarding section 115JB treatment of 14A disallowance was dismissed.</description>
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