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The ITAT upheld the CIT(A)'s deletion of disallowances under sections 80IC and 10AA relating to allocation of indirect Head Office expenses, relying on precedent from the assessee's own case. Regarding foreign travel and club expenses, the Tribunal reduced the disallowance to 10% and 20% respectively, modifying the CIT(A)'s higher percentages, thereby partially allowing the assessee's grounds. The disallowance under section 10AA on scrap sales was deleted, as the sales were held connected to export activities, consistent with prior coordinate bench rulings. The section 14A disallowance was upheld per coordinate bench decisions favoring the assessee, resulting in dismissal of the Revenue's ground. Finally, the disallowance of depreciation on software licenses was rejected, affirming the CIT(A)'s reliance on established precedent. Consequently, the appeal was partly allowed in favor of the assessee with consequential relief granted.
The ITAT upheld the CIT(A)'s deletion of disallowances under sections 80IC and 10AA relating to allocation of indirect Head Office expenses, relying on precedent from the assessee's own case. Regarding foreign travel and club expenses, the Tribunal reduced the disallowance to 10% and 20% respectively, modifying the CIT(A)'s higher percentages, thereby partially allowing the assessee's grounds. The disallowance under section 10AA on scrap sales was deleted, as the sales were held connected to export activities, consistent with prior coordinate bench rulings. The section 14A disallowance was upheld per coordinate bench decisions favoring the assessee, resulting in dismissal of the Revenue's ground. Finally, the disallowance of depreciation on software licenses was rejected, affirming the CIT(A)'s reliance on established precedent. Consequently, the appeal was partly allowed in favor of the assessee with consequential relief granted.
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