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ITAT remanded several issues back to AO for verification including disallowances under sections 14A, 43B, and 35. The Tribunal allowed the assessee's appeal regarding signing amount of grant received, treating it as a liability pending project execution. Foreign commission expenditure was ruled in favor of the assessee, finding no TDS applicability under section 195 as services were rendered outside India. Exchange fluctuation matters were restored to AO for examination under section 43A to determine treatment of capital assets versus WIP. Section 35(2AB) deduction claim was remanded for verification of DSIR approval and compliance. The Tribunal emphasized proper verification of evidence and mandated opportunity of hearing following principles of natural justice across remanded issues.
ITAT remanded several issues back to AO for verification including disallowances under sections 14A, 43B, and 35. The Tribunal allowed the assessee's appeal regarding signing amount of grant received, treating it as a liability pending project execution. Foreign commission expenditure was ruled in favor of the assessee, finding no TDS applicability under section 195 as services were rendered outside India. Exchange fluctuation matters were restored to AO for examination under section 43A to determine treatment of capital assets versus WIP. Section 35(2AB) deduction claim was remanded for verification of DSIR approval and compliance. The Tribunal emphasized proper verification of evidence and mandated opportunity of hearing following principles of natural justice across remanded issues.
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