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    <title>2017 (11) TMI 247 - ITAT DELHI</title>
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    <description>Foreign exchange fluctuation loss on revenue transactions was treated as deductible revenue loss, and depreciation was allowed on assets kept ready for business use. Section 10A relief could not be denied merely for want of further STPI approval where the unit was already registered and supporting permission documents existed. Contribution to an approved gratuity fund fell within the statutory exception to section 40A(7), so the disallowance was deleted. Advances and security deposits written off required further factual verification and were remitted for examination. Payments for inspection and re-working services rendered in the USA were not taxable in India under article 12(4)(b) of the India-US DTAA, so no withholding disallowance arose under section 40(a)(i).</description>
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      <link>https://www.taxtmi.com/caselaws?id=350368</link>
      <description>Foreign exchange fluctuation loss on revenue transactions was treated as deductible revenue loss, and depreciation was allowed on assets kept ready for business use. Section 10A relief could not be denied merely for want of further STPI approval where the unit was already registered and supporting permission documents existed. Contribution to an approved gratuity fund fell within the statutory exception to section 40A(7), so the disallowance was deleted. Advances and security deposits written off required further factual verification and were remitted for examination. Payments for inspection and re-working services rendered in the USA were not taxable in India under article 12(4)(b) of the India-US DTAA, so no withholding disallowance arose under section 40(a)(i).</description>
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