https://www.taxtmi.com/caselaws?id=310925 ITAT Ranchi held that re-opening assessment under sections 147/148 was invalid as LTA provision information was already available in audited books, constituting no new tangible material. The tribunal allowed write-off of technical know-how expenses under section 37(1) as admissible business expenditure since complete technology transfer was not accomplished due to market unavailability. Warranty expense provisions were permitted based on contractual obligations and past experience. Disallowance under section 40(a) for non-deduction of TDS was rejected as the assessee had already added back expenses where TDS wasn't deducted, preventing double addition. Horticulture expenditure was allowed as business expenditure under commercial expediency test. Revenue appeals dismissed. en-us Fri, 05 Apr 2019 00:00:00 +0530 Mon, 27 Nov 2023 05:53:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310925 ITAT Ranchi held that re-opening assessment under sections 147/148 was invalid as LTA provision information was already available in audited books, constituting no new tangible material. The tribunal allowed write-off of technical know-how expenses under section 37(1) as admissible business expenditure since complete technology transfer was not accomplished due to market unavailability. Warranty expense provisions were permitted based on contractual obligations and past experience. Disallowance under section 40(a) for non-deduction of TDS was rejected as the assessee had already added back expenses where TDS wasn't deducted, preventing double addition. Horticulture expenditure was allowed as business expenditure under commercial expediency test. Revenue appeals dismissed. Case-Laws Income Tax Fri, 05 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310925