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    <title>2011 (2) TMI 1414 - ITAT BANGALORE</title>
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    <description>The Tribunal upheld the assessee&#039;s claim for depreciation on software purchases, rejecting the assessing authority&#039;s characterization of the payments as Royalty. Market promotion expenses were allowed for payments to foreign companies without a Permanent Establishment, while FCCB issue expenses were deemed revenue in nature. Telecommunication charges were adjusted in favor of the assessee, aligning with the ITAT Chennai Special Bench decision. The assessee&#039;s appeal for A.Y. 2005-06 was dismissed, but allowed for A.Y. 2006-07. The Revenue&#039;s appeals for both years were dismissed.</description>
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      <title>2011 (2) TMI 1414 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=178790</link>
      <description>The Tribunal upheld the assessee&#039;s claim for depreciation on software purchases, rejecting the assessing authority&#039;s characterization of the payments as Royalty. Market promotion expenses were allowed for payments to foreign companies without a Permanent Establishment, while FCCB issue expenses were deemed revenue in nature. Telecommunication charges were adjusted in favor of the assessee, aligning with the ITAT Chennai Special Bench decision. The assessee&#039;s appeal for A.Y. 2005-06 was dismissed, but allowed for A.Y. 2006-07. The Revenue&#039;s appeals for both years were dismissed.</description>
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