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    <title>2025 (6) TMI 1620 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai dismissed revenue&#039;s appeal regarding TDS non-deduction on foreign payments under section 40(a)(i) and unexplained expenditure under section 69C. CIT(A)&#039;s deletion of additions was upheld after finding TDS was properly deducted as evidenced in Form 26AS showing Rs. 5,29,04,162/- TDS payment. Additionally, software expenses were correctly treated as revenue expenditure for IT support services and license fees rather than capital expenditure for acquiring software rights, as licenses were renewable annually without creating permanent rights.</description>
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      <description>ITAT Mumbai dismissed revenue&#039;s appeal regarding TDS non-deduction on foreign payments under section 40(a)(i) and unexplained expenditure under section 69C. CIT(A)&#039;s deletion of additions was upheld after finding TDS was properly deducted as evidenced in Form 26AS showing Rs. 5,29,04,162/- TDS payment. Additionally, software expenses were correctly treated as revenue expenditure for IT support services and license fees rather than capital expenditure for acquiring software rights, as licenses were renewable annually without creating permanent rights.</description>
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