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    <title>2025 (5) TMI 615 - ITAT DELHI</title>
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    <description>ITAT Delhi allowed the assessee&#039;s appeal regarding disallowed royalty and interest payments. The tribunal found that liability crystallized during the relevant assessment year through settlement with Philips, making it current year expenditure rather than prior period expense. The expenditure was subject to TDS and consistently allowed as revenue expenditure previously. The matter was restored to AO for fresh adjudication with additional evidence. MAT credit issue was also remanded for factual verification and proper computation.</description>
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      <link>https://www.taxtmi.com/caselaws?id=770343</link>
      <description>ITAT Delhi allowed the assessee&#039;s appeal regarding disallowed royalty and interest payments. The tribunal found that liability crystallized during the relevant assessment year through settlement with Philips, making it current year expenditure rather than prior period expense. The expenditure was subject to TDS and consistently allowed as revenue expenditure previously. The matter was restored to AO for fresh adjudication with additional evidence. MAT credit issue was also remanded for factual verification and proper computation.</description>
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