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    <title>2026 (7) TMI 1694 - ITAT MUMBAI</title>
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    <description>Sales-promotion expenditure is distinguished between legitimate business-promotion activities and prohibited travel or hotel benefits directly provided to medical practitioners. The notes address the need for corroborative evidence before sustaining search-based allegations of inflated purchases, and treat manufacturing scrap and empty-container receipts as linked to eligible industrial operations. They describe excise-duty refunds under an industrialisation incentive scheme as capital in nature, and examine transfer-pricing adjustments through functional comparability, reliable market adjustments and evidence of services rendered. They also cover interest-free funds and exempt-income investments under section 14A, foreign tax credit ceilings, and verification of in-house research expenditure. The stated ratio requires reliable comparability or corroborative evidence for transfer-pricing and search-based additions.</description>
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