https://www.taxtmi.com/caselaws?id=456336 The ITAT Bangalore upheld the CIT(A)'s decision treating Data Automation Software expenses as revenue expenditure, finding no asset creation or ownership rights. Software license costs from parent company were similarly allowed as revenue expenses. In transfer pricing matters, the Tribunal applied the 17.50% profit margin from the Bilateral Advance Price Agreement with US entity to Malaysian transactions, excluded non-comparable companies from benchmarking analysis, and dismissed Revenue's appeal on marketing support services adjustments. The assessee's claim for information technology support services was allowed as revenue expenditure. Loans and advances written off were permitted as business loss deduction under sections 28 and 29, despite rejection under sections 36(1)(vii) and 37(1). en-us Tue, 17 May 2022 00:00:00 +0530 Fri, 03 Apr 2026 12:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456336 The ITAT Bangalore upheld the CIT(A)'s decision treating Data Automation Software expenses as revenue expenditure, finding no asset creation or ownership rights. Software license costs from parent company were similarly allowed as revenue expenses. In transfer pricing matters, the Tribunal applied the 17.50% profit margin from the Bilateral Advance Price Agreement with US entity to Malaysian transactions, excluded non-comparable companies from benchmarking analysis, and dismissed Revenue's appeal on marketing support services adjustments. The assessee's claim for information technology support services was allowed as revenue expenditure. Loans and advances written off were permitted as business loss deduction under sections 28 and 29, despite rejection under sections 36(1)(vii) and 37(1). Case-Laws Income Tax Tue, 17 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456336