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    <title>2026 (9) TMI 432 - ITAT MUMBAI</title>
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    <description>Irrecoverable VAT/CST refund claims arising after sales returns may be deductible as business losses where the tax has been refunded to customers and the loss directly arises from ordinary business activity, even if it is not a bad debt. Export-sale receivables written off after goods are rejected and returned for quality defects may qualify as bad debts where the sales were recognised as income and the amounts are actually written off in the accounts; an earlier year of sale does not by itself defeat the claim. For exempt-income expenditure, availability of own funds may preclude interest disallowance, but administrative expenses may still be disallowed under Rule 8D where the taxpayer&#039;s computation is not accepted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=798406</link>
      <description>Irrecoverable VAT/CST refund claims arising after sales returns may be deductible as business losses where the tax has been refunded to customers and the loss directly arises from ordinary business activity, even if it is not a bad debt. Export-sale receivables written off after goods are rejected and returned for quality defects may qualify as bad debts where the sales were recognised as income and the amounts are actually written off in the accounts; an earlier year of sale does not by itself defeat the claim. For exempt-income expenditure, availability of own funds may preclude interest disallowance, but administrative expenses may still be disallowed under Rule 8D where the taxpayer&#039;s computation is not accepted.</description>
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