https://www.taxtmi.com/caselaws?id=432344 Primary evidence cannot be displaced by presumption: software charges tied to recurring maintenance and usage were remitted for fresh examination because the record showed relevant agreements, invoices and allocation details, although some factual gaps remained. Ad hoc disallowance of travelling, conveyance and legal/professional es was unsustainable where additional invoices were verified and no specific defect was shown, so the addition was deleted. Interest expenditure also could not be capitalised as work-in-progress cost absent evidence that borrowed funds were diverted to capital work; the disallowance was deleted. The appeal was thus allowed in part, with statistical relief on the remanded software issue. en-us Mon, 19 Dec 2022 00:00:00 +0530 Tue, 03 Jan 2023 09:45:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432344 Primary evidence cannot be displaced by presumption: software charges tied to recurring maintenance and usage were remitted for fresh examination because the record showed relevant agreements, invoices and allocation details, although some factual gaps remained. Ad hoc disallowance of travelling, conveyance and legal/professional es was unsustainable where additional invoices were verified and no specific defect was shown, so the addition was deleted. Interest expenditure also could not be capitalised as work-in-progress cost absent evidence that borrowed funds were diverted to capital work; the disallowance was deleted. The appeal was thus allowed in part, with statistical relief on the remanded software issue. Case-Laws Income Tax Mon, 19 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432344