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ITAT allows relief to the assessee in part and against the Revenue in part. Depreciation on electrical fittings is confirmed at 10% (not 15%), treating such installations as "furniture and fittings." Addition for foreign-exchange loss allocated by turnover is deleted and CIT(A)'s reversal is restored where losses are identifiable and claimed on actuals. Disallowance under s.40(a)(ia) is negated: late deposit of TDS where tax is deposited before the return filing due date is not disallowable, and CIT(A)'s curative-construction is affirmed. Apportionment of R&D expenses to EOUs is deleted, where the assessee had booked R&D costs to those units. AO's pre-set-off of carried-forward business loss prior to granting s.10B deduction is disapproved and CIT(A)'s treatment is upheld.
ITAT allows relief to the assessee in part and against the Revenue in part. Depreciation on electrical fittings is confirmed at 10% (not 15%), treating such installations as "furniture and fittings." Addition for foreign-exchange loss allocated by turnover is deleted and CIT(A)'s reversal is restored where losses are identifiable and claimed on actuals. Disallowance under s.40(a)(ia) is negated: late deposit of TDS where tax is deposited before the return filing due date is not disallowable, and CIT(A)'s curative-construction is affirmed. Apportionment of R&D expenses to EOUs is deleted, where the assessee had booked R&D costs to those units. AO's pre-set-off of carried-forward business loss prior to granting s.10B deduction is disapproved and CIT(A)'s treatment is upheld.
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