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    <title>2026 (5) TMI 893 - ITAT MUMBAI</title>
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    <description>Professional fees paid for facilitating foreign remittances in connection with imports were held allowable as business expenditure under section 37(1) because the payments were routed through banking channels, tax was deducted at source, and the recipient confirmed the transactions with supporting records. The assessee also showed that OFAC-related banking delays affected Iranian-origin imports and that the services helped expedite remittances, improve the payment cycle, and support turnover and profits. The revenue&#039;s objections rested on assumptions about the recipient&#039;s business profile and infrastructure, without independent inquiry to prove the payments were sham, fictitious, or circulated back to the assessee. The disallowance was deleted.</description>
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      <description>Professional fees paid for facilitating foreign remittances in connection with imports were held allowable as business expenditure under section 37(1) because the payments were routed through banking channels, tax was deducted at source, and the recipient confirmed the transactions with supporting records. The assessee also showed that OFAC-related banking delays affected Iranian-origin imports and that the services helped expedite remittances, improve the payment cycle, and support turnover and profits. The revenue&#039;s objections rested on assumptions about the recipient&#039;s business profile and infrastructure, without independent inquiry to prove the payments were sham, fictitious, or circulated back to the assessee. The disallowance was deleted.</description>
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