https://www.taxtmi.com/caselaws?id=775620 The ITAT upheld the CIT(A)'s decisions in favor of the assessee on multiple grounds. Expenditure on software licenses and renewals used in routine business was held to be revenue in nature, not capital. Interest disallowance based on notional allocation to capital work-in-progress was deleted, as the assessee's interest-free funds sufficiently covered capital investments. Consultancy fees related to recurring export operations were also held to be revenue expenses allowable under section 37(1). Foreign exchange fluctuation loss on advances for capital asset acquisition was confirmed as capital in nature under section 43A, requiring capitalization. The Revenue's appeals were dismissed for lack of evidence contradicting the CIT(A)'s findings, affirming that the expenditures in question did not create enduring capital assets except the foreign exchange loss which must be capitalized. en-us Thu, 24 Jul 2025 00:00:00 +0530 Mon, 28 Jul 2025 08:27:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775620 The ITAT upheld the CIT(A)'s decisions in favor of the assessee on multiple grounds. Expenditure on software licenses and renewals used in routine business was held to be revenue in nature, not capital. Interest disallowance based on notional allocation to capital work-in-progress was deleted, as the assessee's interest-free funds sufficiently covered capital investments. Consultancy fees related to recurring export operations were also held to be revenue expenses allowable under section 37(1). Foreign exchange fluctuation loss on advances for capital asset acquisition was confirmed as capital in nature under section 43A, requiring capitalization. The Revenue's appeals were dismissed for lack of evidence contradicting the CIT(A)'s findings, affirming that the expenditures in question did not create enduring capital assets except the foreign exchange loss which must be capitalized. Case-Laws Income Tax Thu, 24 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775620