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ITAT ruled on multiple taxation issues for the assessee engaged in software development. The tribunal partially allowed the assessee's appeals, addressing key points: (1) computers used for software production qualify as plant and machinery eligible for additional depreciation under Section 32(1)(iia), (2) investment allowances under Section 32AC are permissible for computers used in software development, not administrative purposes, (3) suo-moto disallowance under Section 14A was accepted, (4) foreign tax deduction was allowed following precedent, and (5) MAT credit issue was remanded to Assessing Officer for fresh adjudication. The appeals were predominantly decided in favor of the assessee, with directions for detailed verification by the AO.
ITAT ruled on multiple taxation issues for the assessee engaged in software development. The tribunal partially allowed the assessee's appeals, addressing key points: (1) computers used for software production qualify as plant and machinery eligible for additional depreciation under Section 32(1)(iia), (2) investment allowances under Section 32AC are permissible for computers used in software development, not administrative purposes, (3) suo-moto disallowance under Section 14A was accepted, (4) foreign tax deduction was allowed following precedent, and (5) MAT credit issue was remanded to Assessing Officer for fresh adjudication. The appeals were predominantly decided in favor of the assessee, with directions for detailed verification by the AO.
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