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2016 (3) TMI 1215 - ITAT MUMBAIALP adjustment in respect of the issuance of corporate guarantees - Held that:- Vide our order of even date, which is deemed to be attached and forming part of this order as well, we have deleted similar disallowance for the assessment year 2009-10. We see no reasons to take any other view of the matter for this year. Respectfully following the said order, we uphold the grievance of the assessee and direct the Assessing Officer to delete the impugned ALP adjustment Disallowance under section 14A - Held that:- When there is no income in the hands of the assessee, which is exempt from tax, there cannot be any occasion to make disallowance under section 14A. This was so held by Hon’ble Delhi High Court in the case of CIT vs. Winsome Textile Industries Ltd (2009 (8) TMI 220 - PUNJAB AND HARYANA HIGH COURT ) - Thus addition deleted. - Decided in favour of assessee Deduction u/s. 80IB(8A) allowed. Disallowance of expenses on MS Office licence - Held that:- The amount paid is only an annual licence fees for use of software, the expenses so incurred is required to be treated as revenue expenditure. No material has been brought on record to demolish, or even dispute, this finding of fact. In view of these discussions, and bearing in mind entirety of the case, we approve the order of the CIT(A) on this point as well.
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