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    <title>2025 (2) TMI 1753 - ITAT DELHI</title>
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    <description>Advances written off were treated as business loss because they were incidental to business, following the assessee&#039;s own earlier years&#039; orders, and the disallowance was deleted. ESOP expenditure was accepted as a deductible business expense on the same consistent approach, and that disallowance was also deleted. Foreign remittances were held to fall within treaty protection or reimbursement character, so no TDS liability arose and the section 40(a)(i) disallowance was removed. Interest on income-tax refund was held taxable in the year of receipt, not in the year under appeal, so the corresponding addition was deleted. The Revenue&#039;s challenge failed on all counts.</description>
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      <link>https://www.taxtmi.com/caselaws?id=468086</link>
      <description>Advances written off were treated as business loss because they were incidental to business, following the assessee&#039;s own earlier years&#039; orders, and the disallowance was deleted. ESOP expenditure was accepted as a deductible business expense on the same consistent approach, and that disallowance was also deleted. Foreign remittances were held to fall within treaty protection or reimbursement character, so no TDS liability arose and the section 40(a)(i) disallowance was removed. Interest on income-tax refund was held taxable in the year of receipt, not in the year under appeal, so the corresponding addition was deleted. The Revenue&#039;s challenge failed on all counts.</description>
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