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    <title>2023 (6) TMI 393 - ITAT DELHI</title>
    <link>https://www.taxtmi.com/caselaws?id=438819</link>
    <description>The Tribunal upheld the deletion of penalties under Section 271(1)(c) for AY 2004-05 and 2005-06, citing the debatable nature of the non-compete fee issue. Disallowance of non-compete fee was upheld for AY 2008-09 and 2009-10, while disallowance of provision for reimbursement of sales tax was affirmed. However, disallowance of traffic rule violation expenses was deleted. Expenditure on Ice Boxes was upheld as capital in nature. The issue of processing charges disallowance was remanded for further examination. Disallowance under Section 40(a)(ia) for software purchase without TDS deduction was deleted. The Tribunal dismissed Revenue&#039;s appeals for AY 2004-05 and 2005-06, partially allowed assessee&#039;s appeals for AY 2008-09 and 2009-10, and allowed Revenue&#039;s appeal for AY 2008-09 and 2009-10 for statistical purposes.</description>
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    <pubDate>Wed, 07 Jun 2023 00:00:00 +0530</pubDate>
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      <title>2023 (6) TMI 393 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=438819</link>
      <description>The Tribunal upheld the deletion of penalties under Section 271(1)(c) for AY 2004-05 and 2005-06, citing the debatable nature of the non-compete fee issue. Disallowance of non-compete fee was upheld for AY 2008-09 and 2009-10, while disallowance of provision for reimbursement of sales tax was affirmed. However, disallowance of traffic rule violation expenses was deleted. Expenditure on Ice Boxes was upheld as capital in nature. The issue of processing charges disallowance was remanded for further examination. Disallowance under Section 40(a)(ia) for software purchase without TDS deduction was deleted. The Tribunal dismissed Revenue&#039;s appeals for AY 2004-05 and 2005-06, partially allowed assessee&#039;s appeals for AY 2008-09 and 2009-10, and allowed Revenue&#039;s appeal for AY 2008-09 and 2009-10 for statistical purposes.</description>
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      <pubDate>Wed, 07 Jun 2023 00:00:00 +0530</pubDate>
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