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    <title>2025 (9) TMI 1368 - ITAT MUMBAI</title>
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    <description>ITAT MUMBAI dismissed the revenue&#039;s grounds and allowed most contested claims. Expenditure on replacement dies/moulds, jigs and fixtures, and software were held revenue in nature and deductible. Penalty charges from suppliers were treated as capital receipts. Upfront premium on 99-year leasehold land was accepted as capital and to be amortised; prior-period liabilities debited on invoice receipt were upheld and deleted from additions. Deduction under s.80IA was allowed after adjusting pre-assessment losses; s.14A disallowance under Rule 8D was deleted (administrative disallowance limited to 2% of exempt income). Transfer-pricing, DEPB export benefit taxability, and provisions for doubtful debts were remitted to AO/TPO for fresh consideration consistent with law.</description>
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      <description>ITAT MUMBAI dismissed the revenue&#039;s grounds and allowed most contested claims. Expenditure on replacement dies/moulds, jigs and fixtures, and software were held revenue in nature and deductible. Penalty charges from suppliers were treated as capital receipts. Upfront premium on 99-year leasehold land was accepted as capital and to be amortised; prior-period liabilities debited on invoice receipt were upheld and deleted from additions. Deduction under s.80IA was allowed after adjusting pre-assessment losses; s.14A disallowance under Rule 8D was deleted (administrative disallowance limited to 2% of exempt income). Transfer-pricing, DEPB export benefit taxability, and provisions for doubtful debts were remitted to AO/TPO for fresh consideration consistent with law.</description>
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