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    <title>2025 (10) TMI 690 - ITAT KOLKATA</title>
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    <description>ITAT KOLKATA upheld CIT(A) that writing back previously disallowed amounts would otherwise cause double taxation, rejecting Revenue&#039;s ground. AO&#039;s disallowance of leave-encashment provision was sustained in principle, but the assessee is to get credit for actual leave payments when giving effect. Revenue&#039;s royalty disallowance was dismissed on consistency; similar royalty payments were accepted in adjacent years. Transfer-pricing upward adjustment for advisory/technical services to an AE was rejected-services found rendered and at arm&#039;s length. River-bank/renovation additions and warranty provision claims were allowed. Unpaid leave liability issue decided against the assessee. DDT/DTAA issue remanded to the AO for reconsideration.</description>
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    <pubDate>Wed, 23 Jul 2025 00:00:00 +0530</pubDate>
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      <title>2025 (10) TMI 690 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=779894</link>
      <description>ITAT KOLKATA upheld CIT(A) that writing back previously disallowed amounts would otherwise cause double taxation, rejecting Revenue&#039;s ground. AO&#039;s disallowance of leave-encashment provision was sustained in principle, but the assessee is to get credit for actual leave payments when giving effect. Revenue&#039;s royalty disallowance was dismissed on consistency; similar royalty payments were accepted in adjacent years. Transfer-pricing upward adjustment for advisory/technical services to an AE was rejected-services found rendered and at arm&#039;s length. River-bank/renovation additions and warranty provision claims were allowed. Unpaid leave liability issue decided against the assessee. DDT/DTAA issue remanded to the AO for reconsideration.</description>
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      <pubDate>Wed, 23 Jul 2025 00:00:00 +0530</pubDate>
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