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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 — Neither the Assessing Officer nor the CIT (A) has commented on the computation of the assessee, thus, apparently, the satisfaction to be recorded by the Assessing Officer is completely absent and, therefore, in absence of the required satisfaction, such disallowance could not have been made - DEPUTY CIT V/s NESTLE INDIA LTD. - [2020] 27 ITCD Online 047 (ITAT-DELHI)

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