https://www.taxtmi.com/caselaws?id=752162 The ITAT Delhi ruled on multiple issues involving an assessee company. The tribunal dismissed the claim for DDT refund, following the Mumbai Special Bench precedent that domestic companies must pay DDT at Section 115-O rates regardless of DTAA provisions. For Section 10A/10AA deductions, the tribunal favored the assessee on computation methods, requiring parallel reductions in numerator and denominator, following SC precedent. The tribunal sustained CIT(A)'s decision allowing 95% of shared cost recoveries while treating 5% as non-eligible profit. Interest income from deposits and loans qualified for deductions as business income. Foreign exchange and forward contract gains were deemed eligible for deductions due to direct nexus with export sales. Customer discount provisions and computer peripheral depreciation claims were allowed, with the tribunal dismissing revenue's appeals on these grounds. en-us Mon, 29 Apr 2024 00:00:00 +0530 Sat, 04 May 2024 08:00:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752162 The ITAT Delhi ruled on multiple issues involving an assessee company. The tribunal dismissed the claim for DDT refund, following the Mumbai Special Bench precedent that domestic companies must pay DDT at Section 115-O rates regardless of DTAA provisions. For Section 10A/10AA deductions, the tribunal favored the assessee on computation methods, requiring parallel reductions in numerator and denominator, following SC precedent. The tribunal sustained CIT(A)'s decision allowing 95% of shared cost recoveries while treating 5% as non-eligible profit. Interest income from deposits and loans qualified for deductions as business income. Foreign exchange and forward contract gains were deemed eligible for deductions due to direct nexus with export sales. Customer discount provisions and computer peripheral depreciation claims were allowed, with the tribunal dismissing revenue's appeals on these grounds. Case-Laws Income Tax Mon, 29 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752162