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    <title>2026 (5) TMI 1262 - ITAT DELHI</title>
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    <description>Compensatory interest paid for delayed licence and migration fee was treated as revenue expenditure because it did not create a new asset or enduring advantage. Section 14A read with Rule 8D was held inapplicable where no exempt income was earned during the year. A CSR-related payment to an institution approved under section 80G was regarded as eligible for deduction under Chapter VIA, with no statutory bar merely because the payment satisfied a CSR obligation. Depreciation was also allowed on an intangible asset representing acquired workforce under a genuine slump sale, as such business or commercial rights were held to fall within section 32(1)(ii).</description>
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      <link>https://www.taxtmi.com/caselaws?id=792060</link>
      <description>Compensatory interest paid for delayed licence and migration fee was treated as revenue expenditure because it did not create a new asset or enduring advantage. Section 14A read with Rule 8D was held inapplicable where no exempt income was earned during the year. A CSR-related payment to an institution approved under section 80G was regarded as eligible for deduction under Chapter VIA, with no statutory bar merely because the payment satisfied a CSR obligation. Depreciation was also allowed on an intangible asset representing acquired workforce under a genuine slump sale, as such business or commercial rights were held to fall within section 32(1)(ii).</description>
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