Deduction u/s 80P(2)(a)(i) and 80P(2)(d) on bank interest remanded for AO's verification, including classification of compulsory investments and relat...
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
Note: It is a system-generated summary and is for quick reference only.