Assessment remitted to AO for de novo review of software expense, MTM forex loss and concession fee; secs 43AA, 43B

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....The ITAT remitted the dispute over software expenditure to the AO for de novo fact-finding and adjudication, directing consideration of the software expense breakup submitted by the assessee and the ratio of the jurisdictional HC; the revenue's appeal is allowed for statistical purposes only. The Tribunal allowed the assessee's cross-objection on the concession fee, holding it admissible without invoking section 43B. The ITAT admitted additional evidence for MTM loss claimed under section 43AA, observed such forex losses are in principle allowable, and restored the matter to the AO for verification and fresh adjudication.....