Computational errors in assessment were held rectifiable as apparent from record, since deduction under s.80-IA was disallowed twice to the extent already added via TP adjustment, Chapter VI-A deduction and MAT credit were wrongly computed, and income was taken from s.143(1) intimation instead of revised return; AO was directed to rectify and recompute demand/refund. In TP for management support services, functionally dissimilar/government and credit-rating comparables were excluded, resulting in assessee's margin being at arm's length; TP adjustment was deleted. Reimbursement of software costs from AEs at cost was held not to warrant mark-up; adjustment was deleted. SEB rate (not IEX) was adopted for captive power transfers; related TP adjustments were deleted. Absence of exempt income barred s.14A disallowance (including under MAT); disallowance was deleted. Enhanced s.80-IA claim and interest on receivables were remanded for verification. - ITAT
Computational errors in assessment were held rectifiable as apparent from record, since deduction under s.80-IA was disallowed twice to the extent already added via TP adjustment, Chapter VI-A deduction and MAT credit were wrongly computed, and income was taken from s.143(1) intimation instead of revised return; AO was directed to rectify and recompute demand/refund. In TP for management support services, functionally dissimilar/government and credit-rating comparables were excluded, resulting in assessee's margin being at arm's length; TP adjustment was deleted. Reimbursement of software costs from AEs at cost was held not to warrant mark-up; adjustment was deleted. SEB rate (not IEX) was adopted for captive power transfers; related TP adjustments were deleted. Absence of exempt income barred s.14A disallowance (including under MAT); disallowance was deleted. Enhanced s.80-IA claim and interest on receivables were remanded for verification. - ITAT
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