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    <title>2026 (7) TMI 281 - ITAT MUMBAI</title>
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    <description>Franchise rights were treated as an intangible asset under section 32(1)(ii), and depreciation was to be computed on the full franchise consideration as actual cost, not merely on instalments paid during the year. Cash daily allowance payments to players were held to fall within section 40A(3) and not within Rule 6DD. Business research expenditure and a payment routed through Agilysis for Mr. Ranjit Barthakur were disallowed under section 37(1) for want of proof of actual services and business nexus, while an ad hoc 25% disallowance of web support expenses was deleted as unsupported by material. Hotel/accommodation reimbursements and payments to Blenheim Chalcot Management Ltd. were remanded for verification. Security expenses were accepted as incurred for business and allowed on commercial expediency grounds.</description>
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