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    <title>2023 (7) TMI 368 - ITAT AMRITSAR</title>
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    <description>The Tribunal found in favor of the appellant, emphasizing the importance of passing a speaking order and addressing all grounds of appeal. It held that the non-speaking order by the CIT(A) was against natural justice and bad in law. The disallowance of 25% of royalty expenses as capital expenditure was overturned, with the Tribunal noting the failure to consider relevant case laws. The reassessment under Section 143(3) read with Section 263 was deemed valid, emphasizing the need for due inquiry and application of mind. The matter was remanded to the CIT(A) for a fresh adjudication on the royalty expense claim, with directions to pass a speaking order.</description>
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      <description>The Tribunal found in favor of the appellant, emphasizing the importance of passing a speaking order and addressing all grounds of appeal. It held that the non-speaking order by the CIT(A) was against natural justice and bad in law. The disallowance of 25% of royalty expenses as capital expenditure was overturned, with the Tribunal noting the failure to consider relevant case laws. The reassessment under Section 143(3) read with Section 263 was deemed valid, emphasizing the need for due inquiry and application of mind. The matter was remanded to the CIT(A) for a fresh adjudication on the royalty expense claim, with directions to pass a speaking order.</description>
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