2021 (2) TMI 1202

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....d by the revenue against the order of the ld. CIT(A)-39 , New Delhi dated 26 .05.2017 . 2. Following grounds have been raised by the revenue: "1. Whether on the facts and circumstances o f the case & in law, the Ld. CIT(A) erred in deleting the addition of Rs. 38,12,375/- made on account of 'disallowance on account of payment o f Royalty' vide order u/s 143(3) of the I .T . Act 1961 passed b....

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....ent dated 01.06 .2005 treating the Royalty payment as capital expenditure . The AO further relied on the orders of the ld. CIT (A) for the earlier years . The disallowance was agitated before the ld. CIT (A) who has allowed the appeal of the assessee on the grounds that the similar disallowance made by the AO was allowed in favour of the assessee by the jurisdictional ITAT New Delhi in ITA Nos. 63....