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    <title>2023 (9) TMI 1117 - ITAT PANAJI</title>
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    <description>The Department&#039;s appeal regarding the disallowance of royalty under Section 43B of the Income Tax Act was dismissed, as the Tribunal upheld the CIT(A)&#039;s decision that royalty had been paid before the return filing date. The appeal on the suppression of sale value and under-invoicing was also dismissed, with the Tribunal finding the transactions at arm&#039;s length. However, the appeal on the disallowance of conversion charges under Section 37(1) was allowed, as the expenses were deemed revenue in nature. Consequently, the Revenue&#039;s appeals were dismissed, and the assessee&#039;s appeal was allowed.</description>
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      <title>2023 (9) TMI 1117 - ITAT PANAJI</title>
      <link>https://www.taxtmi.com/caselaws?id=443495</link>
      <description>The Department&#039;s appeal regarding the disallowance of royalty under Section 43B of the Income Tax Act was dismissed, as the Tribunal upheld the CIT(A)&#039;s decision that royalty had been paid before the return filing date. The appeal on the suppression of sale value and under-invoicing was also dismissed, with the Tribunal finding the transactions at arm&#039;s length. However, the appeal on the disallowance of conversion charges under Section 37(1) was allowed, as the expenses were deemed revenue in nature. Consequently, the Revenue&#039;s appeals were dismissed, and the assessee&#039;s appeal was allowed.</description>
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