The ITAT upheld the disallowance of royalty payments made to an...

The ITAT upheld the disallowance of royalty payments made to an entity not holding the registered trademark, deeming such expenses not wholly and exclusively for business purposes and indicative of tax avoidance, thereby dismissing that ground of appeal. Conversely, the tribunal allowed the deduction of consultancy fees paid to unrelated professionals, recognizing these as necessary and bona fide business expenses for running the school. Additionally, the ITAT accepted the assessee's explanation regarding a typographical error in lease documentation and allowed the claim for additional rent, supported by substantial revenue growth and increased operational scale. Thus, the appeal was partly allowed, with disallowance of royalty payments sustained, while consultancy expenses and additional rent claims were permitted.