Section 10A and related deductions: Tribunal rejects separate-undertaking claim, but allows loss set-off, ESOP cost and foreign tax credit in principl...
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Non-debit of partners' remuneration and interest did not affect eligibility for deduction under section 10AA where the resulting business profit remained eligible, so the deletion of the addition was justified. The note also records that reassessment cannot travel beyond the recorded reasons: reopening was based on discrepancy in import figures, no addition was made on that issue, and the addition on partners' remuneration and interest was outside the permissible scope. The Revenue's appeal was dismissed on both grounds.
Non-debit of partners' remuneration and interest did not affect eligibility for deduction under section 10AA where the resulting business profit remained eligible, so the deletion of the addition was justified. The note also records that reassessment cannot travel beyond the recorded reasons: reopening was based on discrepancy in import figures, no addition was made on that issue, and the addition on partners' remuneration and interest was outside the permissible scope. The Revenue's appeal was dismissed on both grounds.
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