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    <title>2026 (8) TMI 1030 - ITAT MUMBAI</title>
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    <description>Commission expenditure paid to agents for procuring business from pharmaceutical companies qualifies for deduction under Section 37(1) where it is incurred wholly and exclusively for business purposes. The required business nexus was supported by the linkage between the payments and commission income earned, verification of recipients&#039; identities, payment through banking channels, tax deducted at source, and recipients&#039; disclosure of the income in their tax returns. In the absence of material showing fictitious payments, non-existent recipients, or return of funds to the payer, the expenditure is treated as genuine and allowable as a business deduction.</description>
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      <link>https://www.taxtmi.com/caselaws?id=797156</link>
      <description>Commission expenditure paid to agents for procuring business from pharmaceutical companies qualifies for deduction under Section 37(1) where it is incurred wholly and exclusively for business purposes. The required business nexus was supported by the linkage between the payments and commission income earned, verification of recipients&#039; identities, payment through banking channels, tax deducted at source, and recipients&#039; disclosure of the income in their tax returns. In the absence of material showing fictitious payments, non-existent recipients, or return of funds to the payer, the expenditure is treated as genuine and allowable as a business deduction.</description>
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