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    <title>2025 (9) TMI 1126 - ITAT KOLKATA</title>
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    <description>ITAT, Kolkata - AT allowed the assessee&#039;s appeal in full and set aside the AO&#039;s and ld. CIT(A)&#039;s additions/disallowances. Interest on advances was held allowable as funds were for business use and interest-free funds covered loans. Payments to a non-resident without PE in India in foreign currency were held not liable to TDS under s.195. Estimated disallowances for cash purchases, assembling charges, gold usage and car expenses were deleted for lack of basis or consistency with prior years and proper books. A 50% commission disallowance to relatives was deleted for want of comparative proof of unreasonableness.</description>
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      <description>ITAT, Kolkata - AT allowed the assessee&#039;s appeal in full and set aside the AO&#039;s and ld. CIT(A)&#039;s additions/disallowances. Interest on advances was held allowable as funds were for business use and interest-free funds covered loans. Payments to a non-resident without PE in India in foreign currency were held not liable to TDS under s.195. Estimated disallowances for cash purchases, assembling charges, gold usage and car expenses were deleted for lack of basis or consistency with prior years and proper books. A 50% commission disallowance to relatives was deleted for want of comparative proof of unreasonableness.</description>
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