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2017 (2) TMI 1000 - AT - Income TaxDisallowance of consultancy charges incurred on designing and implementation of TDS and other systems - nature of expenditure - Held that:- Keeping in view of the argument advanced by the parties and by going through the record carefully, it came into the notice that the assessee is in the business of manufacturing, purchasing, processing and refining crop protection goods etc. The expenditure was incurred for the improving and rationalizing of system such as TDS and Works Contract Tax System, Security Deposit Management System, Excel Vouchers upload systems, inferface of auto-booking of excise / CENVAT to BayMAP system, sales tax administration – sales, sales tax administration – purchases, maintaining capital work in progress, forex payable and leased assets etc. In view of the said facts and circumstances, it is quite clear that it is revenue expenditure and the case of the assessee is fairly covered by the law settled in Commissioner of Income Tax Vs. Raychem RPG Ltd. [2011 (7) TMI 953 - Bombay High Court ] - Decided in favour of assessee Disallowance u/s.14A to the extent of 10% of the total exempted income - Held that:- From the facts and figures mentioned above, it noticed that own fund is more than the investment, therefore in the said circumstances no expenditure is required to be deducted in view of the law settled in Hon’ble Bombay High Court in the case of Reliance Utilities and Power Ltd. (2009 (1) TMI 4 - BOMBAY HIGH COURT ), accordingly, we delete the expenditure assessed by the CIT(A) in view of the provision u/s.14A of the Act. Accordingly, this issue is decided in favour of the assessee
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