Disallowance of royalty payment & TDS u/s 195 upheld in favor of assessee. No disallowance u/s 14A r.w.r.8D. ESI contribution payment issue restored to CIT(A).

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....The ITAT Delhi ruled in favor of the assessee on various issues. The disallowance of royalty payment was deemed genuine based on a trademark agreement and sales linkage. TDS u/s 195 disallowance was rejected as per precedent. No disallowance u/s 14A r.w.r.8D due to no dividend income. ESI contribution delay was upheld based on a Supreme Court judgment. The issue of ESI payment date was referred back to CIT(A) for fresh consideration. Income understatement was justified due to TDS deductions in previous years. The Revenue's appeal was partly allowed.....