Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestab...
Diagnostic microcuvette classification follows sole-use analytical function, placing specialised disposable cuvettes with their analyser rather than g...
Customs Broker licensing proceedings fail when their offence-report foundation collapses and authorisation, advisory, and KYC duties remain unbreached...
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Software license expenses incurred by the assessee were held to be revenue expenditure based on the coordinate bench's decision in DCIT v/s M/s First Advantage Private Limited for the preceding year. Regarding disallowance u/s 40(a)(ia), the assessee admitted deducting TDS at a lower rate on Rs. 98,363 and offered 30% of this amount for disallowance. The CIT(A) rightly deleted the disallowance made by the AO, as the assessee had already disallowed 30% of the relevant payments. The ITAT affirmed the CIT(A)'s order on this issue.
Software license expenses incurred by the assessee were held to be revenue expenditure based on the coordinate bench's decision in DCIT v/s M/s First Advantage Private Limited for the preceding year. Regarding disallowance u/s 40(a)(ia), the assessee admitted deducting TDS at a lower rate on Rs. 98,363 and offered 30% of this amount for disallowance. The CIT(A) rightly deleted the disallowance made by the AO, as the assessee had already disallowed 30% of the relevant payments. The ITAT affirmed the CIT(A)'s order on this issue.
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