https://www.taxtmi.com/caselaws?id=443492 ITAT Mumbai partly allowed assessee's appeal and dismissed revenue's appeal regarding multiple deductions and transfer pricing issues. The tribunal allowed deduction for payments to Clayton Christensen Institute as business expenditure under section 37(1) since it involved employee training benefiting business, but disallowed Royal Hospital sponsorship lacking business nexus. Advertisement expenses and section 10AA deduction computation were remitted for fresh consideration. Foreign tax credit was allowed for nine specified countries. State taxes paid in USA were held deductible if not covered under tax treaties. TDS provisions on imported software were held inapplicable based on copyright analysis. Section 14A disallowance was deleted for lack of objective satisfaction by AO. Transfer pricing adjustments on software services were upheld, while loan provisions and guarantee issues were remitted. Brand royalty adjustment was deleted since assessee didn't own the brand. en-us Fri, 15 Sep 2023 00:00:00 +0530 Mon, 30 Jun 2025 11:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=443492 ITAT Mumbai partly allowed assessee's appeal and dismissed revenue's appeal regarding multiple deductions and transfer pricing issues. The tribunal allowed deduction for payments to Clayton Christensen Institute as business expenditure under section 37(1) since it involved employee training benefiting business, but disallowed Royal Hospital sponsorship lacking business nexus. Advertisement expenses and section 10AA deduction computation were remitted for fresh consideration. Foreign tax credit was allowed for nine specified countries. State taxes paid in USA were held deductible if not covered under tax treaties. TDS provisions on imported software were held inapplicable based on copyright analysis. Section 14A disallowance was deleted for lack of objective satisfaction by AO. Transfer pricing adjustments on software services were upheld, while loan provisions and guarantee issues were remitted. Brand royalty adjustment was deleted since assessee didn't own the brand. Case-Laws Income Tax Fri, 15 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=443492