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    <title>2019 (10) TMI 1637 - ITAT LUCKNOW</title>
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    <description>Electricity transmission charges were treated as not subject to tax deduction at source as fees for technical services, so disallowance for non-deduction of tax could not be made on that basis. The deletion of the related disallowance remained intact because earlier years&#039; treatment disclosed no distinguishing facts. Expenditure disallowance linked to exempt income required fresh factual verification because the earlier basis for deletion had been remitted for reconsideration. The Assessing Officer must examine whether exempt income was earned and, if so, the applicability and quantification of the disallowance.</description>
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      <description>Electricity transmission charges were treated as not subject to tax deduction at source as fees for technical services, so disallowance for non-deduction of tax could not be made on that basis. The deletion of the related disallowance remained intact because earlier years&#039; treatment disclosed no distinguishing facts. Expenditure disallowance linked to exempt income required fresh factual verification because the earlier basis for deletion had been remitted for reconsideration. The Assessing Officer must examine whether exempt income was earned and, if so, the applicability and quantification of the disallowance.</description>
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