Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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The ITAT held that the assessee bank was eligible for deduction u/s 36(1)(viia) for its rural branches. The Assessing Officer had erroneously rejected the rural branch status for five branches based on district-wise data from the 2011 Census. However, the assessee appropriately relied on the final village-wise data from the 2001 Census to claim the deduction, as the 2011 Census lacked village-level population figures. The ITAT found no error in the impugned appellate order allowing the deduction and dismissed the revenue's appeal.
The ITAT held that the assessee bank was eligible for deduction u/s 36(1)(viia) for its rural branches. The Assessing Officer had erroneously rejected the rural branch status for five branches based on district-wise data from the 2011 Census. However, the assessee appropriately relied on the final village-wise data from the 2001 Census to claim the deduction, as the 2011 Census lacked village-level population figures. The ITAT found no error in the impugned appellate order allowing the deduction and dismissed the revenue's appeal.
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