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ITAT partially allowed the appeal. In the transfer pricing dispute, the tribunal directed the TPO to exclude XS CAD India Private Limited from comparables, recognizing functional dissimilarities in software development services. Regarding corporate tax, the tribunal upheld the assessee's donation deduction under Section 80G, finding compliance with Companies Act CSR provisions and Income Tax Act requirements. The decision emphasized that denying the 80G deduction would result in gross injustice, thereby granting relief to the assessee and mandating the Assessing Officer to allow the deduction subject to statutory conditions.
ITAT partially allowed the appeal. In the transfer pricing dispute, the tribunal directed the TPO to exclude XS CAD India Private Limited from comparables, recognizing functional dissimilarities in software development services. Regarding corporate tax, the tribunal upheld the assessee's donation deduction under Section 80G, finding compliance with Companies Act CSR provisions and Income Tax Act requirements. The decision emphasized that denying the 80G deduction would result in gross injustice, thereby granting relief to the assessee and mandating the Assessing Officer to allow the deduction subject to statutory conditions.
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