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    <title>2025 (9) TMI 158 - ITAT PATNA</title>
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    <description>An ad hoc disallowance of expenditure was deleted because the rejection reasons were too exacting and the record did not support denial of deduction under section 37(1). The addition under section 40(a)(ia) was sustained because tax was deductible under Chapter XVII-B on payments for arranging purchase of paddy, and the characterization dispute between section 194C and section 194H did not alter that position; the assessee also failed to produce supporting contractual material. Partial relief was therefore granted only on the expenditure issue.</description>
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      <description>An ad hoc disallowance of expenditure was deleted because the rejection reasons were too exacting and the record did not support denial of deduction under section 37(1). The addition under section 40(a)(ia) was sustained because tax was deductible under Chapter XVII-B on payments for arranging purchase of paddy, and the characterization dispute between section 194C and section 194H did not alter that position; the assessee also failed to produce supporting contractual material. Partial relief was therefore granted only on the expenditure issue.</description>
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