https://www.taxtmi.com/caselaws?id=448082 ITAT Mumbai-AT dismissed revenue's appeal regarding interest disallowance under section 36(1)(iii), following Bombay HC precedent in Reliance Utilities that presumption favors investment from interest-free funds when sufficient funds available. Assessee's appeal on lease rental disallowance was allowed for statistical purposes, with matter restored to AO for fresh examination after cyber attack prevented document submission. Software expenses appeal succeeded, with ITAT directing AO to treat annual license fees and maintenance as revenue expenses following prior tribunal decision. However, assessee's claim for MFN clause benefits for dividend distribution tax to Dutch shareholders was rejected, as Supreme Court in Nestle case mandated specific notification under section 90/1 for MFN clause application. en-us Tue, 31 Oct 2023 00:00:00 +0530 Wed, 10 Jan 2024 14:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448082 ITAT Mumbai-AT dismissed revenue's appeal regarding interest disallowance under section 36(1)(iii), following Bombay HC precedent in Reliance Utilities that presumption favors investment from interest-free funds when sufficient funds available. Assessee's appeal on lease rental disallowance was allowed for statistical purposes, with matter restored to AO for fresh examination after cyber attack prevented document submission. Software expenses appeal succeeded, with ITAT directing AO to treat annual license fees and maintenance as revenue expenses following prior tribunal decision. However, assessee's claim for MFN clause benefits for dividend distribution tax to Dutch shareholders was rejected, as Supreme Court in Nestle case mandated specific notification under section 90/1 for MFN clause application. Case-Laws Income Tax Tue, 31 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448082