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ITAT ruled in favor of the assessee, comprehensively addressing multiple taxation issues. The tribunal deleted disallowances under section 14A and section 115JB, finding no legal foundation for the Assessing Officer's additions. The tribunal accepted the assessee's R&D expenditure claim under section 35(1)(iv), allowing deduction for capital expenditure in the approved scientific research facility. For TDS under section 195, the tribunal held that testing services by non-resident vendors did not constitute taxable income in India, as services were purely certification-based, did not transfer technical knowledge, and were utilized for export transactions. Consequently, the tribunal directed deletion of TDS-related disallowances and provided substantial relief to the assessee across multiple taxation grounds.
ITAT ruled in favor of the assessee, comprehensively addressing multiple taxation issues. The tribunal deleted disallowances under section 14A and section 115JB, finding no legal foundation for the Assessing Officer's additions. The tribunal accepted the assessee's R&D expenditure claim under section 35(1)(iv), allowing deduction for capital expenditure in the approved scientific research facility. For TDS under section 195, the tribunal held that testing services by non-resident vendors did not constitute taxable income in India, as services were purely certification-based, did not transfer technical knowledge, and were utilized for export transactions. Consequently, the tribunal directed deletion of TDS-related disallowances and provided substantial relief to the assessee across multiple taxation grounds.
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