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    <title>2023 (1) TMI 652 - ITAT DELHI</title>
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    <description>Tax treatment of share capital, aircraft-related payments and assorted expenditure depends on the applicable statutory or treaty character of the receipt or outlay, and additions cannot be finally sustained where the factual foundation is incomplete. Share application money from two subscribers was remitted for fresh verification on identity, creditworthiness and genuineness. Leasing and maintenance payments were held not to attract section 40(a)(i), while software expenditure was treated as capital with depreciation already allowed. FCCB issue and redemption costs, as well as pilot training and licence expenditure, were treated as revenue outgoings. Related-party rent was deleted, and the section 14A matter was remitted for factual verification.</description>
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