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    <title>2026 (5) TMI 407 - ITAT MUMBAI</title>
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    <description>Disallowance under section 40(a)(ia) is not attracted where the impugned expenditure has not been claimed as a deduction in the profit and loss account for the relevant year but has been capitalised to work-in-progress. The accounting method used, including percentage completion or completed contract, does not by itself control the position; the decisive factor is whether the expenditure entered the computation of income for that year. Where part of the amount remains in closing work-in-progress, the proper treatment is adjustment of work-in-progress to the extent needed, rather than a direct addition to total income.</description>
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