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    <title>2024 (6) TMI 1579 - ITAT HYDERABAD</title>
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    <description>Third-party service payments supported by invoices, ledgers, bank records, PAN details and other evidence were treated as genuine, and the absence of replies to earlier notices was not enough to disallow the entire claim under section 37 when the remand report raised no adverse finding and the books were not rejected. Head office overheads and business development expenses were noted as outside section 44C where they are exclusively attributable to the Indian project or PE, so verification of the factual attribution was required; the separate disallowance under section 40(a)(i) remained undisturbed because it was not specifically challenged. A write-off for short receipt from NHAI also required verification of prior recognition and tax treatment of the related income before it could be allowed as bad debt or business loss.</description>
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      <description>Third-party service payments supported by invoices, ledgers, bank records, PAN details and other evidence were treated as genuine, and the absence of replies to earlier notices was not enough to disallow the entire claim under section 37 when the remand report raised no adverse finding and the books were not rejected. Head office overheads and business development expenses were noted as outside section 44C where they are exclusively attributable to the Indian project or PE, so verification of the factual attribution was required; the separate disallowance under section 40(a)(i) remained undisturbed because it was not specifically challenged. A write-off for short receipt from NHAI also required verification of prior recognition and tax treatment of the related income before it could be allowed as bad debt or business loss.</description>
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