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    <title>2023 (6) TMI 107 - ITAT MUMBAI</title>
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    <description>The Tribunal ruled in favor of the assessee, setting aside the order passed under section 263. It held that the EDP expenses were correctly treated as revenue expenditure by the Assessing Officer, rejecting the Principal Commissioner of Income Tax&#039;s contention that they should be capitalized. The Tribunal also upheld the treatment of royalty expenses as revenue in nature, finding that the TDS was indeed deducted. The Tribunal deemed the order under section 263 unjustified, as the Assessing Officer had conducted adequate inquiries, leading to the appeal being allowed and the section 263 order being quashed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=438533</link>
      <description>The Tribunal ruled in favor of the assessee, setting aside the order passed under section 263. It held that the EDP expenses were correctly treated as revenue expenditure by the Assessing Officer, rejecting the Principal Commissioner of Income Tax&#039;s contention that they should be capitalized. The Tribunal also upheld the treatment of royalty expenses as revenue in nature, finding that the TDS was indeed deducted. The Tribunal deemed the order under section 263 unjustified, as the Assessing Officer had conducted adequate inquiries, leading to the appeal being allowed and the section 263 order being quashed.</description>
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