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    <title>2025 (7) TMI 755 - ITAT DELHI</title>
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    <description>ITAT Delhi dismissed assessee&#039;s appeal regarding royalty payments to G.D. Goenka Pvt. Ltd., finding the payments were not legitimate business expenses since the company did not hold the registered trademark/patent rights, which belonged to an individual. The arrangement appeared to be tax planning to shift profits from trust to private company. However, ITAT allowed consultancy charges as genuine business expenses for running the school, supported by proper documentation and TDS deduction. Additional rent claim was also allowed despite typographical errors in documentation, as substantial revenue increase from Rs. 9.37 crores to Rs. 19.88 crores demonstrated genuine business expansion requiring additional space.</description>
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