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    <title>2024 (3) TMI 1115 - ITAT DELHI</title>
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    <description>Transfer pricing adjustment was deleted because it had to be confined to the value of international transactions and the comparables did not justify an adjustment on the assessee&#039;s entire turnover. Section 43B claims received mixed treatment: covered statutory dues were allowed on the basis of earlier orders, while some items such as RG 23A balances and withdrawal of earlier add-backs were remanded for verification. Disallowance under Section 14A was deleted for lack of proximate nexus with exempt income. Deduction for VRS expenditure under Section 35DDA was allowed, and payments for services rendered outside India were held outside Section 40(a)(ia) because no withholding obligation arose. Sales tax subsidy was treated as capital receipt, brought-forward depreciation was to be considered under amended Section 32(2), and several stock, consumption, speculative loss and club expenditure additions were either deleted or left undisturbed.</description>
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      <description>Transfer pricing adjustment was deleted because it had to be confined to the value of international transactions and the comparables did not justify an adjustment on the assessee&#039;s entire turnover. Section 43B claims received mixed treatment: covered statutory dues were allowed on the basis of earlier orders, while some items such as RG 23A balances and withdrawal of earlier add-backs were remanded for verification. Disallowance under Section 14A was deleted for lack of proximate nexus with exempt income. Deduction for VRS expenditure under Section 35DDA was allowed, and payments for services rendered outside India were held outside Section 40(a)(ia) because no withholding obligation arose. Sales tax subsidy was treated as capital receipt, brought-forward depreciation was to be considered under amended Section 32(2), and several stock, consumption, speculative loss and club expenditure additions were either deleted or left undisturbed.</description>
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