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Ground raised by the department that on the facts and in the circumstances of thecaseand in law, the Ld. CIT (A) has erred in deleting the addition of Rs. 61,01,74,000/- made on account of licence fee.

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Sec. 14A of Income Tax Act, 1961—Business Disallowance — Before making any disallowance under the provisions of Section 14A read with Rule-8D, the Assessing Officer has to record a finding that he is not satisfied with the correctness of the claim of the expenditure incurred and in the of assessee, such satisfaction was not recorded, thus, disallowance delted - DEPUTY CIT V/s NESTLE INDIA LTD. - [2020] 207 TTJ 369 (ITAT-DELHI)

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