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    <title>2025 (5) TMI 960 - ITAT MUMBAI</title>
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    <description>The ITAT Mumbai upheld the CIT(A)&#039;s decision to delete disallowances made by the AO regarding Section 10AA deductions and Section 40(a)(ia) TDS provisions. For the 10AA deduction, the tribunal found that the assessee maintained separate books for two units serving different countries (US and Europe), with export freight charges and foreign travel expenses properly allocated to respective units with adequate documentation. The AO failed to examine the unit-wise expense breakup and supporting evidence. Regarding TDS disallowance, the tribunal confirmed that when advance payments were considered, there was no short deduction of tax at source, supported by Form 16A and Form 26AS. The revenue&#039;s appeal was dismissed on both grounds.</description>
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    <pubDate>Wed, 30 Apr 2025 00:00:00 +0530</pubDate>
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      <title>2025 (5) TMI 960 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=770688</link>
      <description>The ITAT Mumbai upheld the CIT(A)&#039;s decision to delete disallowances made by the AO regarding Section 10AA deductions and Section 40(a)(ia) TDS provisions. For the 10AA deduction, the tribunal found that the assessee maintained separate books for two units serving different countries (US and Europe), with export freight charges and foreign travel expenses properly allocated to respective units with adequate documentation. The AO failed to examine the unit-wise expense breakup and supporting evidence. Regarding TDS disallowance, the tribunal confirmed that when advance payments were considered, there was no short deduction of tax at source, supported by Form 16A and Form 26AS. The revenue&#039;s appeal was dismissed on both grounds.</description>
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      <pubDate>Wed, 30 Apr 2025 00:00:00 +0530</pubDate>
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