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    <title>2025 (9) TMI 615 - ITAT AHMEDABAD</title>
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    <description>ITAT A&#039;bad held that commission paid to a foreign agent was not taxable in India as no PE or business connection existed here and services were rendered outside India; DTAA support led to deletion of TDS-based disallowance. Reimbursement of a director&#039;s medical expenses, authorized by board resolution and in discharge of contractual obligations, was allowed as business expenditure under s.37(1). Disallowance under s.14A r.w. Rule 8D was not warranted beyond the exempt dividend income; no interest disallowance was made. An addition based on Form 26AS mismatch was set aside and remitted to the AO to verify whether the amount was already offered to tax in the relevant year. Warranty provision was held allowable if rational and compliant with AS-29.</description>
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