https://www.taxtmi.com/caselaws?id=311855 ITAT Ahmedabad upheld CIT(A)'s decision treating replacement expenses on plant and machinery, technology fees, and repair/maintenance expenditures as revenue nature. Bad debt write-offs were allowed following statutory amendments. Depreciation on data processing machines was not apportioned between DTA and EOU units as no evidence showed EOU usage. SAP R3 license fees were confirmed as revenue expenditure. Transfer pricing adjustment on royalty payments was remanded to CIT(A) for fresh adjudication. Section 80HHC deduction computation was reversed, excluding 100% EOU profits per judicial precedent. Interest on tax refund was held taxable. Professional fees for routine renovation were allowed as revenue expenditure, while architectural fees were remanded. TDS disallowance under section 40(a)(ia) on foreign supply credit interest was upheld for non-compliance with section 195. en-us Mon, 24 Apr 2017 00:00:00 +0530 Wed, 17 Jan 2024 21:07:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311855 ITAT Ahmedabad upheld CIT(A)'s decision treating replacement expenses on plant and machinery, technology fees, and repair/maintenance expenditures as revenue nature. Bad debt write-offs were allowed following statutory amendments. Depreciation on data processing machines was not apportioned between DTA and EOU units as no evidence showed EOU usage. SAP R3 license fees were confirmed as revenue expenditure. Transfer pricing adjustment on royalty payments was remanded to CIT(A) for fresh adjudication. Section 80HHC deduction computation was reversed, excluding 100% EOU profits per judicial precedent. Interest on tax refund was held taxable. Professional fees for routine renovation were allowed as revenue expenditure, while architectural fees were remanded. TDS disallowance under section 40(a)(ia) on foreign supply credit interest was upheld for non-compliance with section 195. Case-Laws Income Tax Mon, 24 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311855