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    <title>2014 (6) TMI 707 - ITAT CHENNAI</title>
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    <description>Remittances for international leased circuit and related telecommunication services were treated as royalty where the payment covered use of telecom equipment and process for assured connectivity, requiring tax deduction at source and supporting disallowance for non-deduction. For section 10A computation, foreign currency and telecommunication expenses had to be excluded from both export turnover and total turnover, while brought-forward losses of the eligible unit were not to be set off before computing the deduction. Rule 8D under section 14A was held inapplicable retrospectively, though a limited disallowance remained. Interest under section 234D was not leviable for the relevant year, and a provision for expenses was allowed as an accrued business liability, not a contingent liability.</description>
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      <title>2014 (6) TMI 707 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=248803</link>
      <description>Remittances for international leased circuit and related telecommunication services were treated as royalty where the payment covered use of telecom equipment and process for assured connectivity, requiring tax deduction at source and supporting disallowance for non-deduction. For section 10A computation, foreign currency and telecommunication expenses had to be excluded from both export turnover and total turnover, while brought-forward losses of the eligible unit were not to be set off before computing the deduction. Rule 8D under section 14A was held inapplicable retrospectively, though a limited disallowance remained. Interest under section 234D was not leviable for the relevant year, and a provision for expenses was allowed as an accrued business liability, not a contingent liability.</description>
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