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    <title>Pre-operative costs held revenue; s.35(2AB) weighted deduction allowed for DSIR-approved R&amp;D abroad; s.40(a)(i) additions sustained</title>
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    <description>ITAT held that the appellant&#039;s pre-operative expenditure is revenue in nature and not required to be capitalised for tax purposes. The Tribunal directed allowance of weighted deduction under s.35(2AB) for DSIR-approved R&amp;D expenses incurred abroad and at Limda (Vadodara). Additions under s.40(a)(i) for failure to deduct TDS on payments to a foreign AE were sustained, the AO having not established reimbursement status. Foreign-exchange reversal credited to P&amp;L was deleted under s.43A. Year-end provisions and an advance write-back were remanded to the AO for factual verification. Expenditure on gifts was allowed. TPO&#039;s benchmarking of a corporate guarantee was reduced to 0.5%; other benchmarking issues were remanded.</description>
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    <pubDate>Mon, 15 Sep 2025 08:26:13 +0530</pubDate>
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      <title>Pre-operative costs held revenue; s.35(2AB) weighted deduction allowed for DSIR-approved R&amp;D abroad; s.40(a)(i) additions sustained</title>
      <link>https://www.taxtmi.com/highlights?id=92527</link>
      <description>ITAT held that the appellant&#039;s pre-operative expenditure is revenue in nature and not required to be capitalised for tax purposes. The Tribunal directed allowance of weighted deduction under s.35(2AB) for DSIR-approved R&amp;D expenses incurred abroad and at Limda (Vadodara). Additions under s.40(a)(i) for failure to deduct TDS on payments to a foreign AE were sustained, the AO having not established reimbursement status. Foreign-exchange reversal credited to P&amp;L was deleted under s.43A. Year-end provisions and an advance write-back were remanded to the AO for factual verification. Expenditure on gifts was allowed. TPO&#039;s benchmarking of a corporate guarantee was reduced to 0.5%; other benchmarking issues were remanded.</description>
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      <pubDate>Mon, 15 Sep 2025 08:26:13 +0530</pubDate>
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