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    <title>2026 (6) TMI 1157 - ITAT MUMBAI</title>
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    <description>Expenditure incurred by an insurance company for outsourcing-related payments was treated as allowable because disallowance under Explanation 1 to section 37(1) requires material showing an offence or an act prohibited by law, and no punitive action by the competent regulator or other authority was shown. The commentary also states that section 14A read with Rule 8D does not apply to insurance business, because section 44 with the First Schedule provides a special, overriding computation scheme for such income. On that basis, the described additions were deleted, while the reassessment challenge was left academic.</description>
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