https://www.taxtmi.com/caselaws?id=755608 ITAT Mumbai ruled on multiple tax issues. Software license fees were held to be revenue expenditure due to periodic nature, not creating enduring benefits. Section 14A disallowance under rule 8D was partially deleted where own funds exceeded exempt investments. Transfer pricing adjustments were made for counter guarantees to associated enterprises at 0.5% and delayed receivables at LIBOR+100 basis points after 60 days credit period. Warranty provisions were remanded for verification of actual expenditure. Amalgamation expenses under section 35DD must be claimed in 1/5th installments over 5 years. UPS depreciation was allowed at 60% as computer accessory. Various other issues were remanded for fresh consideration by assessing officer. en-us Mon, 04 Dec 2023 00:00:00 +0530 Mon, 15 Jul 2024 12:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755608 ITAT Mumbai ruled on multiple tax issues. Software license fees were held to be revenue expenditure due to periodic nature, not creating enduring benefits. Section 14A disallowance under rule 8D was partially deleted where own funds exceeded exempt investments. Transfer pricing adjustments were made for counter guarantees to associated enterprises at 0.5% and delayed receivables at LIBOR+100 basis points after 60 days credit period. Warranty provisions were remanded for verification of actual expenditure. Amalgamation expenses under section 35DD must be claimed in 1/5th installments over 5 years. UPS depreciation was allowed at 60% as computer accessory. Various other issues were remanded for fresh consideration by assessing officer. Case-Laws Income Tax Mon, 04 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755608