https://www.taxtmi.com/caselaws?id=778350 ITAT held that pre-operative expenditure is revenue in nature and should be allowed as claimed, following earlier HC findings. R&D expenditure approved by DSIR qualifies for weighted deduction; AO directed to allow. Addition under s.40(a)(i) for failure to deduct TDS on payments to foreign AE upheld as factual determination was not established. Foreign-exchange gain credited on reversal of earlier disallowed loss deleted. Year-end provisions remanded to AO for factual determination of liability. Advance written back and benchmarking of certain transactions remanded for verification. Corporate guarantee benchmarking reduced to 0.5% of guarantee amount. en-us Mon, 01 Sep 2025 00:00:00 +0530 Sat, 13 Sep 2025 13:23:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778350 ITAT held that pre-operative expenditure is revenue in nature and should be allowed as claimed, following earlier HC findings. R&D expenditure approved by DSIR qualifies for weighted deduction; AO directed to allow. Addition under s.40(a)(i) for failure to deduct TDS on payments to foreign AE upheld as factual determination was not established. Foreign-exchange gain credited on reversal of earlier disallowed loss deleted. Year-end provisions remanded to AO for factual determination of liability. Advance written back and benchmarking of certain transactions remanded for verification. Corporate guarantee benchmarking reduced to 0.5% of guarantee amount. Case-Laws Income Tax Mon, 01 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778350