Expenditure on software license fees paid periodically is revenue in nature and should be allowed as...

Expenditure on software license fees paid periodically is revenue in nature and should be allowed as deduction. No disallowance u/r 8D(2)(ii) warranted when own funds exceed tax-free investments. Disallowance u/r 8D(2)(iii) to be recomputed considering only investments earning tax-free income, excluding growth funds, and suo moto disallowance by assessee. Issue of unutilized MODVAT credit restored to AO for denovo determination as per amended section 145A. Providing counter-guarantee to AE is an international transaction; ALP to be calculated at 0.5%. Delay in receipt of receivables from AE is an international transaction; interest to be charged at LIBOR+100 basis points after 60 days credit period. Provision for warranty remitted to AO to ..... .....

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