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The additions with reference to s. 40(a) of the Act made in the name of the assessee, were rightly deleted by the two appellate authorities in the present case.

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Section 10(15)(iv)(f) & 40(a)(ia) of the Income Tax Act, 1961– Business Disallowance– Assessee had the specific exemption from the Ministry of Finance and therefore was entitled not to deduct any tax at source from the interest payment made by it to LFA Ltd from which assessee took the foreign currency loan in question and therefore section 40(a)(ia) could not attract to the present case at all even though the foreign currency loan was utilized by the assessee to repay the loan. – RE P. Ltd. Commissioner of Income tax vs. Seven Seas Distillery P. Ltd. [2020] 312 CTR (Madras) 272 

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