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    <title>2010 (10) TMI 695 - ITAT, DELHI</title>
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    <description>Adjustment of sundry debtors against a foreign group company liability was not treated as remission or cessation under section 41(1) because the amount had not been allowed as a deduction and the book entry did not amount to trading liability ceasing; the addition was deleted. Reimbursement of communication and leased-line charges paid to the foreign group company was not royalty or fees for technical services, and section 40(a)(i) disallowance for non-deduction of tax was deleted. An alleged revenue-booking error arising from system failure was not accepted because the assessee failed to produce reconciliatory material, so the addition was upheld. Interest under section 234D was held applicable in principle for the period after 1.6.2003, but the matter was remanded for fresh computation.</description>
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    <pubDate>Wed, 13 Oct 2010 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=206773</link>
      <description>Adjustment of sundry debtors against a foreign group company liability was not treated as remission or cessation under section 41(1) because the amount had not been allowed as a deduction and the book entry did not amount to trading liability ceasing; the addition was deleted. Reimbursement of communication and leased-line charges paid to the foreign group company was not royalty or fees for technical services, and section 40(a)(i) disallowance for non-deduction of tax was deleted. An alleged revenue-booking error arising from system failure was not accepted because the assessee failed to produce reconciliatory material, so the addition was upheld. Interest under section 234D was held applicable in principle for the period after 1.6.2003, but the matter was remanded for fresh computation.</description>
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