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    <title>2026 (4) TMI 1903 - ITAT MUMBAI</title>
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    <description>Ad hoc disallowance of professional fees is unsupported where no specific expense is shown not to have been incurred wholly and exclusively for business. Trade-incentive and brand-promotion costs incurred to promote product sales remain revenue expenditure despite any incidental enduring brand benefit. Premises-sharing and third-party letting receipts are treated as income from other sources where that classification applies; notional rent cannot be assessed without evidence of actual receipt or accrual. Building and common expenditure incurred wholly and exclusively to earn such income is deductible under the applicable provisions for income from other sources. Transfer-pricing grounds were not considered on merits because they were not pressed.</description>
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