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    <title>2026 (4) TMI 1465 - ITAT DELHI</title>
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    <description>Omission of clause (i) of section 92BA without a saving clause was treated as retrospective, so transfer pricing adjustment based solely on that deleted provision was held unsustainable. Brokerage paid for procuring tenants was partly allowed as business expenditure under section 37(1) where invoices established direct business nexus, with the balance left for verification. Receipts from car parking, fixed deposits created for business exigencies, permission charges and licence fee were held to have direct nexus with the SEZ undertaking and were allowed as deduction under section 80IAB, rather than being taxed as income from other sources.</description>
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