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    <description>Loss claimed as embezzlement by a closely related manager was not accepted as a business deduction where there was no documentary support, no particulars of the alleged services or recipients, no recovery effort, and the surrounding relationship suggested possible collusion. Payments described as commission to related persons were also disallowed because the assessee produced no bills, agreements, service evidence, or fair-market justification, leaving the assessing officer entitled to treat them as excessive and unreasonable under the related-party payment rule. The reassessment reference was also treated as valid within the applicable limitation framework.</description>
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