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    <description>For Rule 8D disallowance under section 14A, only investments that actually yielded exempt income during the year are to be included, so the computation must be restricted to that base. ESOP discount was treated as a real and ascertained business expenditure deductible under section 37(1), not a contingent or capital outlay, and the disallowance was deleted. Sales incentive expenditure required recipient-wise verification of the payment terms and whether any part was prohibited by law; because the factual record was incomplete, the matter was remanded for fresh examination by the Assessing Officer.</description>
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