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ITAT dismissed revenue's appeal regarding TDS non-deduction on foreign payments under section 40(a)(i) and unexplained expenditure disallowance under section 69C. CIT(A)'s deletion of additions was upheld after assessee provided documentary evidence including Form 26AS showing TDS of Rs. 5,29,04,162/- deducted on payments to foreign entity. Regarding software expenses, ITAT confirmed CIT(A)'s finding that IT support charges constituted revenue expenditure rather than capital expenditure, as payments were for yearly renewable software licenses without acquiring proprietary rights. Revenue failed to controvert factual position with supporting evidence, resulting in dismissal of all grounds.
ITAT dismissed revenue's appeal regarding TDS non-deduction on foreign payments under section 40(a)(i) and unexplained expenditure disallowance under section 69C. CIT(A)'s deletion of additions was upheld after assessee provided documentary evidence including Form 26AS showing TDS of Rs. 5,29,04,162/- deducted on payments to foreign entity. Regarding software expenses, ITAT confirmed CIT(A)'s finding that IT support charges constituted revenue expenditure rather than capital expenditure, as payments were for yearly renewable software licenses without acquiring proprietary rights. Revenue failed to controvert factual position with supporting evidence, resulting in dismissal of all grounds.
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