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    <title>2024 (5) TMI 1563 - ITAT MUMBAI</title>
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    <description>The ITAT Mumbai allowed the assessee&#039;s appeal on multiple grounds. The tribunal directed the AO to treat opening balance of assets transferred in demerger as loss rather than depreciation, following judicial precedent. Computer software license fees were allowed as revenue expenditure based on earlier year decisions. The issue of advance written off for Modvat credit claims was restored to AO for fresh examination with adequate hearing opportunity. The tribunal deleted additions related to 90% exclusion of various receipts while computing business profits, following previous year&#039;s decision. For capital gains on plot transfer, the tribunal directed adoption of fair market value as determined by DVO dated 1-04-1981, consistent with earlier assessment year rulings.</description>
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      <description>The ITAT Mumbai allowed the assessee&#039;s appeal on multiple grounds. The tribunal directed the AO to treat opening balance of assets transferred in demerger as loss rather than depreciation, following judicial precedent. Computer software license fees were allowed as revenue expenditure based on earlier year decisions. The issue of advance written off for Modvat credit claims was restored to AO for fresh examination with adequate hearing opportunity. The tribunal deleted additions related to 90% exclusion of various receipts while computing business profits, following previous year&#039;s decision. For capital gains on plot transfer, the tribunal directed adoption of fair market value as determined by DVO dated 1-04-1981, consistent with earlier assessment year rulings.</description>
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