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Foreign exchange gain from realization of export proceeds for IT/ITES services rendered to associated enterprises was treated as operating income under TNMM, because it arose on revenue account in the normal course of business; the Assessing Officer was directed to verify this linkage, and the remaining transfer pricing grounds were left academic. Donation to Odisha State Disaster Management Authority was held eligible for deduction under section 80G despite being part of CSR expenditure, as there is no general bar outside the statutory exclusions. The foreign tax credit claim under section 90 was restored for verification and consequential grant in accordance with law.
Foreign exchange gain from realization of export proceeds for IT/ITES services rendered to associated enterprises was treated as operating income under TNMM, because it arose on revenue account in the normal course of business; the Assessing Officer was directed to verify this linkage, and the remaining transfer pricing grounds were left academic. Donation to Odisha State Disaster Management Authority was held eligible for deduction under section 80G despite being part of CSR expenditure, as there is no general bar outside the statutory exclusions. The foreign tax credit claim under section 90 was restored for verification and consequential grant in accordance with law.
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