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    <title>2012 (7) TMI 614 - ITAT MUMBAI</title>
    <link>https://www.taxtmi.com/caselaws?id=215115</link>
    <description>The Tribunal partially allowed the assessee&#039;s appeal, dismissing the Revenue&#039;s appeals. The Tribunal found the bad debts write-off to be commercially prudent, following the Supreme Court judgment in TRF Ltd. The disallowance under Section 40(a)(ia) for short deduction of TDS was deleted. The reopening of assessment under Section 147/148 was upheld due to the issue not being examined previously. The non-grant of credit of TDS was sent back for fresh adjudication. The disallowance under Section 14A was directed for reconsideration, while the treatment of software expenditure as capital was not pursued by the assessee.</description>
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    <pubDate>Fri, 25 May 2012 00:00:00 +0530</pubDate>
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      <title>2012 (7) TMI 614 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=215115</link>
      <description>The Tribunal partially allowed the assessee&#039;s appeal, dismissing the Revenue&#039;s appeals. The Tribunal found the bad debts write-off to be commercially prudent, following the Supreme Court judgment in TRF Ltd. The disallowance under Section 40(a)(ia) for short deduction of TDS was deleted. The reopening of assessment under Section 147/148 was upheld due to the issue not being examined previously. The non-grant of credit of TDS was sent back for fresh adjudication. The disallowance under Section 14A was directed for reconsideration, while the treatment of software expenditure as capital was not pursued by the assessee.</description>
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      <pubDate>Fri, 25 May 2012 00:00:00 +0530</pubDate>
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