https://www.taxtmi.com/caselaws?id=308979 The Tribunal upheld the CIT(A)'s decisions on all grounds, dismissing the Revenue's appeal. The deduction under section 10A on foreign exchange fluctuation gain was allowed as it was considered incidental to business operations. Disallowance under section 40(a)(ia) for payments made to parties outside India was deleted, as the entities did not have a Permanent Establishment in India. The disallowance of 20% of recruitment and training charges was also deleted, as they were deemed necessary for business purposes. Additionally, adjustments made by the TPO under section 92CA(3) were deleted, confirming the correct characterization of the assessee's operations. en-us Fri, 12 Apr 2013 00:00:00 +0530 Fri, 04 Aug 2023 12:06:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=308979 The Tribunal upheld the CIT(A)'s decisions on all grounds, dismissing the Revenue's appeal. The deduction under section 10A on foreign exchange fluctuation gain was allowed as it was considered incidental to business operations. Disallowance under section 40(a)(ia) for payments made to parties outside India was deleted, as the entities did not have a Permanent Establishment in India. The disallowance of 20% of recruitment and training charges was also deleted, as they were deemed necessary for business purposes. Additionally, adjustments made by the TPO under section 92CA(3) were deleted, confirming the correct characterization of the assessee's operations. Case-Laws Income Tax Fri, 12 Apr 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=308979