Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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ITAT affirmed the rejection of the assessee's claim that interest on fixed deposits qualified for deduction under section 10AA, holding such interest is taxable as income from other sources unless deposits were made for bona fide business exigencies or to facilitate export operations, and noting consistency where interest had earlier been treated as other income. However, ITAT remanded computation of book profit under section 115JB to the AO for verification and recomputation, and directed fresh adjudication of the s.43B leave-encashment deduction claim to ascertain prior-year disallowance and payment. ITAT also remanded the alleged double addition of interest income for AO verification to ensure correct taxable income assessment.
ITAT affirmed the rejection of the assessee's claim that interest on fixed deposits qualified for deduction under section 10AA, holding such interest is taxable as income from other sources unless deposits were made for bona fide business exigencies or to facilitate export operations, and noting consistency where interest had earlier been treated as other income. However, ITAT remanded computation of book profit under section 115JB to the AO for verification and recomputation, and directed fresh adjudication of the s.43B leave-encashment deduction claim to ascertain prior-year disallowance and payment. ITAT also remanded the alleged double addition of interest income for AO verification to ensure correct taxable income assessment.
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