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    <title>Revenue challenges on expenditure classification dismissed; penalty receipts treated as capital; 80IA relief upheld; 14A disallowance limited</title>
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    <description>ITAT dismissed the revenue&#039;s grounds challenging classification of expenditures on dies, moulds, jigs, fixtures and software as revenue in nature and allowable as deductions; penalty receipts from suppliers were held to be capital receipts and that ground was dismissed. The Tribunal directed deletion of impugned additions, upheld proportionate amortisation of non-refundable premium on 99-year leasehold land, and sustained prior-period charging of crystallised liabilities. Section 80IA deduction was allowed without adjustment for pre-assessment year depreciation and losses. Section 14A disallowance was deleted except administrative disallowance limited to 2% of exempt income. Transfer-pricing and doubtful-debts issues were remitted to AO/TPO for fresh consideration in accordance with law.</description>
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    <pubDate>Wed, 24 Sep 2025 08:08:38 +0530</pubDate>
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      <title>Revenue challenges on expenditure classification dismissed; penalty receipts treated as capital; 80IA relief upheld; 14A disallowance limited</title>
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      <description>ITAT dismissed the revenue&#039;s grounds challenging classification of expenditures on dies, moulds, jigs, fixtures and software as revenue in nature and allowable as deductions; penalty receipts from suppliers were held to be capital receipts and that ground was dismissed. The Tribunal directed deletion of impugned additions, upheld proportionate amortisation of non-refundable premium on 99-year leasehold land, and sustained prior-period charging of crystallised liabilities. Section 80IA deduction was allowed without adjustment for pre-assessment year depreciation and losses. Section 14A disallowance was deleted except administrative disallowance limited to 2% of exempt income. Transfer-pricing and doubtful-debts issues were remitted to AO/TPO for fresh consideration in accordance with law.</description>
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      <pubDate>Wed, 24 Sep 2025 08:08:38 +0530</pubDate>
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