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    <title>2024 (5) TMI 833 - ITAT KOLKATA</title>
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    <description>ITAT Kolkata ruled in favor of the assessee on multiple issues. Patent registration expenses for existing and new patents were held revenue in nature under Section 37. TDS provisions under Section 195 were not applicable to payments to foreign commission agents for services rendered abroad. Liquidated damages for delayed delivery/installation were treated as capital receipts not reducible from asset cost. Section 14A disallowance was restricted to assessee&#039;s suo-motto amount. Interest on tax refunds could be netted against interest on delayed tax payments. Marked-to-market losses on forward contracts were allowable following Supreme Court precedents. Carbon credit sales were characterized as capital receipts and non-taxable.</description>
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