High Court Clarifies Section 40(a)(ia): Disallowance Requires Actual Deduction Claim in Income Tax Computation.

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....Disallowance made under Section 40(a)(ia) - The Sine qua non for the application of Section 40(a)(ia) of the Act to apply is claiming of the amount sought to be disallowed as an expenditure / deduction to determine the taxable income of the assessee - HC....