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ITAT allowed assessee's claim for deduction u/s 10B despite absence of separate books for eligible units, following earlier coordinate bench orders affirmed by Delhi HC, and dismissed Revenue's grounds. In TP, ITAT directed exclusion of specified comparables (Apitco, Cameo Corporate Services, Global Procurement Consultants, Killick Agencies and Marketing, Orient Engineering and Commercial) as functionally dissimilar for the corporate support services segment. ITAT further held, consistent with prior years and Delhi HC/ITAT precedents, that no addition u/s 14A read with Rule 8D is permissible while computing book profits u/s 115JB, and deleted the disallowance u/s 14A for lack of AO's recorded satisfaction. ITAT also permitted enhanced deduction u/s 10B based on suo motu disallowance, holding Goetze (India) inapplicable to appellate powers.
ITAT allowed assessee's claim for deduction u/s 10B despite absence of separate books for eligible units, following earlier coordinate bench orders affirmed by Delhi HC, and dismissed Revenue's grounds. In TP, ITAT directed exclusion of specified comparables (Apitco, Cameo Corporate Services, Global Procurement Consultants, Killick Agencies and Marketing, Orient Engineering and Commercial) as functionally dissimilar for the corporate support services segment. ITAT further held, consistent with prior years and Delhi HC/ITAT precedents, that no addition u/s 14A read with Rule 8D is permissible while computing book profits u/s 115JB, and deleted the disallowance u/s 14A for lack of AO's recorded satisfaction. ITAT also permitted enhanced deduction u/s 10B based on suo motu disallowance, holding Goetze (India) inapplicable to appellate powers.
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