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    <title>2026 (6) TMI 417 - ITAT CHENNAI</title>
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    <description>Expenditure incurred in a one-time settlement with contractors for business restructuring was held allowable in full under section 37 because it was wholly and exclusively for business and did not fall within the distinct amortisation scheme in section 35DDA; the deduction could not be curtailed by importing a one-fifth restriction from employee settlements. The section 14A read with Rule 8D disallowance was set aside for fresh verification because the assessee&#039;s suo motu disallowance and supporting workings were not properly examined. The treaty-based claim relating to dividend distribution tax under section 115O was remitted for reconsideration after the final position on the pending legal issue.</description>
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      <description>Expenditure incurred in a one-time settlement with contractors for business restructuring was held allowable in full under section 37 because it was wholly and exclusively for business and did not fall within the distinct amortisation scheme in section 35DDA; the deduction could not be curtailed by importing a one-fifth restriction from employee settlements. The section 14A read with Rule 8D disallowance was set aside for fresh verification because the assessee&#039;s suo motu disallowance and supporting workings were not properly examined. The treaty-based claim relating to dividend distribution tax under section 115O was remitted for reconsideration after the final position on the pending legal issue.</description>
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