Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
