https://www.taxtmi.com/caselaws?id=784041 Payments treated as commission/brokerage were held not liable to TDS under s.194H on the facts already decided in the assessee's own earlier years; consequently, no disallowance could be made under s.40(a)(ia). Expenditure on items such as pen drives, laptops, cables and hard disks was held to be revenue in nature, following binding co-ordinate bench precedent; the deletion of the capitalisation/disallowance was sustained. Additions from recomputation by disallowing amounts under ss.37-43B (including provisions, prior-period items, loss on sale of assets, etc.), disallowance of write-back of excess provisions, and related s.40(a)(ia) adjustments were deleted as covered by earlier orders. Exempt dividend income under s.10(34) was allowed for an insurer, and s.14A was held inapplicable; reopening on this issue was treated as change of opinion and invalid. Exemption under s.10(15)(iv)(h) and depreciation under s.32 were allowed. en-us Tue, 23 Dec 2025 00:00:00 +0530 Sat, 27 Dec 2025 08:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784041 Payments treated as commission/brokerage were held not liable to TDS under s.194H on the facts already decided in the assessee's own earlier years; consequently, no disallowance could be made under s.40(a)(ia). Expenditure on items such as pen drives, laptops, cables and hard disks was held to be revenue in nature, following binding co-ordinate bench precedent; the deletion of the capitalisation/disallowance was sustained. Additions from recomputation by disallowing amounts under ss.37-43B (including provisions, prior-period items, loss on sale of assets, etc.), disallowance of write-back of excess provisions, and related s.40(a)(ia) adjustments were deleted as covered by earlier orders. Exempt dividend income under s.10(34) was allowed for an insurer, and s.14A was held inapplicable; reopening on this issue was treated as change of opinion and invalid. Exemption under s.10(15)(iv)(h) and depreciation under s.32 were allowed. Case-Laws Income Tax Tue, 23 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784041