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    <title>2019 (8) TMI 1948 - ITAT MUMBAI</title>
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    <description>The dominant issue was disallowance of deduction under s.80IA by invoking s.80IA(10). The Tribunal held that each assessment year is separate and, following its earlier order in the same assessee&#039;s case, the Revenue had not produced material to rebut the factual findings accepted by the first appellate authority; business expenditure and arrangements must be tested from the standpoint of commercial expediency and not on the AO&#039;s subjective view. The disallowance under s.80IA was therefore deleted. A second issue concerned disallowance of managerial support/service charges paid to related parties for alleged lack of demonstrated benefit. Applying the earlier coordinate bench decision on identical facts, the disallowance was deleted.</description>
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    <pubDate>Fri, 02 Aug 2019 00:00:00 +0530</pubDate>
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      <title>2019 (8) TMI 1948 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=465721</link>
      <description>The dominant issue was disallowance of deduction under s.80IA by invoking s.80IA(10). The Tribunal held that each assessment year is separate and, following its earlier order in the same assessee&#039;s case, the Revenue had not produced material to rebut the factual findings accepted by the first appellate authority; business expenditure and arrangements must be tested from the standpoint of commercial expediency and not on the AO&#039;s subjective view. The disallowance under s.80IA was therefore deleted. A second issue concerned disallowance of managerial support/service charges paid to related parties for alleged lack of demonstrated benefit. Applying the earlier coordinate bench decision on identical facts, the disallowance was deleted.</description>
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