Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
ITAT dismissed the Revenue's appeal and upheld the CIT(A)'s orders: the amount characterized as an "arbitration award" was held to be a typographical misclassification of software sale and the related addition was deleted; foreign exchange fluctuation gains were held to be business receipts directly relatable to export of software and therefore eligible for exemption under s.10A; and no disallowance under s.40(a)(ia) was warranted where the assessee had deducted tax at source (albeit at a lower rate) on the buy-back consideration, such deduction being treated as compliance with the TDS obligation. The Revenue's challenge was therefore rejected in entirety.
ITAT dismissed the Revenue's appeal and upheld the CIT(A)'s orders: the amount characterized as an "arbitration award" was held to be a typographical misclassification of software sale and the related addition was deleted; foreign exchange fluctuation gains were held to be business receipts directly relatable to export of software and therefore eligible for exemption under s.10A; and no disallowance under s.40(a)(ia) was warranted where the assessee had deducted tax at source (albeit at a lower rate) on the buy-back consideration, such deduction being treated as compliance with the TDS obligation. The Revenue's challenge was therefore rejected in entirety.
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