Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
ITAT upheld CIT(A)'s decision, allowing normal deduction u/s 35(1)(iv) for R&D capital expenditure disallowed under weighted deduction u/s 35(2AB). The tribunal found the issue consistent with the assessee's previous year's case, affirming that capital expenditure on scientific research at an approved R&D facility remains deductible even if not qualifying for enhanced deduction. Revenue's appeal grounds were comprehensively dismissed, maintaining the lower appellate authority's reasoning and providing tax relief to the assessee.
ITAT upheld CIT(A)'s decision, allowing normal deduction u/s 35(1)(iv) for R&D capital expenditure disallowed under weighted deduction u/s 35(2AB). The tribunal found the issue consistent with the assessee's previous year's case, affirming that capital expenditure on scientific research at an approved R&D facility remains deductible even if not qualifying for enhanced deduction. Revenue's appeal grounds were comprehensively dismissed, maintaining the lower appellate authority's reasoning and providing tax relief to the assessee.
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