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    <title>2026 (8) TMI 38 - ITAT DELHI</title>
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    <description>Tax-deduction disallowance of residual consultancy charges remained sustainable because the supporting material did not show that the amount fell outside the withholding obligation, while substantiated service-tax relief was retained. Interest disallowance was sustained for one payee lacking compliance evidence and remitted for verification for another payee. Expenses crystallising during the relevant year, including invoices issued to an affiliated entity on identical facts, were treated as allowable; prior-period treatment was revenue neutral. Written-off balances, though not allowable as bad debts, qualified as business expenditure or business loss. Customer advances were not unexplained cash credits where identity, genuineness and creditworthiness were established. No disallowance under section 14A and rule 8D applied absent exempt income; deletions of prior-period and business electricity expenses were retained.</description>
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