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    <title>2019 (8) TMI 406 - ITAT DELHI</title>
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    <description>Section 41(1) cannot apply unless the relevant liability or expenditure had earlier been allowed as a deduction or allowance; because no such prior allowance was shown in the predecessor&#039;s hands, the write-back addition was deleted. Tax paid on behalf of foreign suppliers was held to discharge their income-tax liability and was not deductible business expenditure under section 37(1), so the disallowance was sustained. For section 14A, exempt interest income required disallowance of direct board meeting fees and a reasonable administrative disallowance, so the addition was partly enhanced. Software upgradation and machine shifting costs were revenue expenses, and the research and development disallowance was deleted following the assessee&#039;s own case.</description>
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      <title>2019 (8) TMI 406 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=384217</link>
      <description>Section 41(1) cannot apply unless the relevant liability or expenditure had earlier been allowed as a deduction or allowance; because no such prior allowance was shown in the predecessor&#039;s hands, the write-back addition was deleted. Tax paid on behalf of foreign suppliers was held to discharge their income-tax liability and was not deductible business expenditure under section 37(1), so the disallowance was sustained. For section 14A, exempt interest income required disallowance of direct board meeting fees and a reasonable administrative disallowance, so the addition was partly enhanced. Software upgradation and machine shifting costs were revenue expenses, and the research and development disallowance was deleted following the assessee&#039;s own case.</description>
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      <pubDate>Mon, 05 Aug 2019 00:00:00 +0530</pubDate>
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