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    <title>2022 (11) TMI 6 - ITAT DELHI</title>
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    <description>Activities already accepted in earlier assessment years on identical facts were held not to fall within the mischief of section 2(15), so exemption under sections 11 and 12 was upheld. The Tribunal found no distinguishing material from the Revenue and followed the coordinate Bench view. Global Trade Development expenses were found to be incurred to strengthen and promote the Indian IT-BPO industry, and their consistent allowance in earlier and subsequent years supported deductibility; the disallowance was deleted. The CIT(A)&#039;s order was sustained on both issues.</description>
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      <description>Activities already accepted in earlier assessment years on identical facts were held not to fall within the mischief of section 2(15), so exemption under sections 11 and 12 was upheld. The Tribunal found no distinguishing material from the Revenue and followed the coordinate Bench view. Global Trade Development expenses were found to be incurred to strengthen and promote the Indian IT-BPO industry, and their consistent allowance in earlier and subsequent years supported deductibility; the disallowance was deleted. The CIT(A)&#039;s order was sustained on both issues.</description>
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