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ITAT ruled favorably on multiple issues. Section 14A disallowance under Rule 8D(2)(ii) was deleted, while Rule 8D(2)(iii) computation was directed for recalculation considering only exempt income-yielding investments. MAT computation under s.115JB to be recalculated on reasonable basis. TDS under s.194H not required on prepaid distributor discounts, nullifying s.40(a)(ia) disallowance. Depreciation on 3G spectrum allowed under s.32(1)(ii). IBM payment issue remanded for verification of service agreement nature. Transfer pricing adjustments for brand royalty and expense reimbursements remanded to TPO/AO for fresh consideration with directions to examine additional documentation and grant reasonable hearing opportunity.
ITAT ruled favorably on multiple issues. Section 14A disallowance under Rule 8D(2)(ii) was deleted, while Rule 8D(2)(iii) computation was directed for recalculation considering only exempt income-yielding investments. MAT computation under s.115JB to be recalculated on reasonable basis. TDS under s.194H not required on prepaid distributor discounts, nullifying s.40(a)(ia) disallowance. Depreciation on 3G spectrum allowed under s.32(1)(ii). IBM payment issue remanded for verification of service agreement nature. Transfer pricing adjustments for brand royalty and expense reimbursements remanded to TPO/AO for fresh consideration with directions to examine additional documentation and grant reasonable hearing opportunity.
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