Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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