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    <title>2014 (4) TMI 823 - ITAT MUMBAI</title>
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    <description>Employees&#039; state insurance contribution paid before the due date for filing the return was held allowable under section 43B. Claims relating to advances written off, leave encashment write-back, and TDS or treaty-based foreign tax credit were restored for verification because they depended on factual reconciliation and accounting details. The transfer pricing adjustment on technical and licence fees paid to an associated enterprise was deleted, as the royalty or licence fee was accepted as arm&#039;s length on the facts of the assessee&#039;s own earlier years. An additional ground seeking benefit of the India-Switzerland treaty was admitted as a pure question of law and restored for adjudication. The appeals were thus partly allowed for statistical purposes.</description>
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      <link>https://www.taxtmi.com/caselaws?id=246854</link>
      <description>Employees&#039; state insurance contribution paid before the due date for filing the return was held allowable under section 43B. Claims relating to advances written off, leave encashment write-back, and TDS or treaty-based foreign tax credit were restored for verification because they depended on factual reconciliation and accounting details. The transfer pricing adjustment on technical and licence fees paid to an associated enterprise was deleted, as the royalty or licence fee was accepted as arm&#039;s length on the facts of the assessee&#039;s own earlier years. An additional ground seeking benefit of the India-Switzerland treaty was admitted as a pure question of law and restored for adjudication. The appeals were thus partly allowed for statistical purposes.</description>
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