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As evident from grounds of appeal, the assessee is primarily aggrieved on 4 counts viz., (i) Disallowance of non-compete fees for Rs. 8 crores (ii) Quantum of Deduction under s. 80-O; (iii) Disallowance of entertainment expenditure; (iv) Disallowance of travelling expenditure under r. 6D.

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Section 37 of the Income Tax Act, 1961 — Business Expenditure — Non compete fee paid to ward off rival competition in perpetuity is Capital expenditure rightly disallowed by AO — DSP Merrill Lynch Ltd. vs. Joint Commissioner of income tax [2019] 202 TTJ (Mumbai) 762

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