Court Rules on Software Costs, Expat Salaries, and Lease Charges; Calls for Review on Salary Additions and Double Deductions.

The Delhi High Court addressed issues related to reimbursement of software costs, reimbursement of expatriate salaries, and lease registration charges. The court held that the addition made for reimbursement of software costs was not proven as the assessee failed to demonstrate actual receipt and use of software in India for business purposes. Referring to a Supreme Court judgment, it was established that payments to nonresident software suppliers were not royalty and not subject to TDS. The court found the ITAT's deletion of the addition for expatriate salaries lacked sufficient reasoning and required further consideration. Regarding lease registration charges, the ITAT's decision to not amortize them over the lease period was upheld, as r..... .....

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