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    <title>2010 (8) TMI 1070 - ITAT KOLKATA</title>
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    <description>Where appellate relief rests on facts that changed after assessment, fairness required the Assessing Officer&#039;s comments before deletion of the interest disallowance; that issue was restored for fresh adjudication after a remand report. Bad debts were allowable because the advances were made in the ordinary course of money-lending business, were written off as irrecoverable in the accounts, and satisfied the statutory conditions for deduction. Software development expenditure was held revenue in nature because the application software only improved operational efficiency and supported business functions without creating an enduring capital asset. The first issue was remanded, while the bad debt and software disallowances were deleted.</description>
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      <title>2010 (8) TMI 1070 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=189989</link>
      <description>Where appellate relief rests on facts that changed after assessment, fairness required the Assessing Officer&#039;s comments before deletion of the interest disallowance; that issue was restored for fresh adjudication after a remand report. Bad debts were allowable because the advances were made in the ordinary course of money-lending business, were written off as irrecoverable in the accounts, and satisfied the statutory conditions for deduction. Software development expenditure was held revenue in nature because the application software only improved operational efficiency and supported business functions without creating an enduring capital asset. The first issue was remanded, while the bad debt and software disallowances were deleted.</description>
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