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    <title>2025 (3) TMI 708 - ITAT KOLKATA</title>
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    <description>ITAT Kolkata allowed the appeal in favor of the assessee on multiple grounds. The tribunal excluded two comparables (Tata Elexi Limited and Sasken Technologies Ltd.) from TP analysis, reducing the average margin to 11.66% and bringing the assessee&#039;s 9.44% margin within the acceptable 3% range, eliminating TP adjustment requirements. TP adjustments for intra-group services and advertisement expenses were deleted based on previous favorable decisions. Section 14A disallowance was removed as no exempt income was earned. Double addition under section 41(1) was corrected, and lease rental disallowance was deleted following precedent. Section 80G deduction was allowed for CSR contributions.</description>
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    <pubDate>Tue, 11 Mar 2025 00:00:00 +0530</pubDate>
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      <title>2025 (3) TMI 708 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=767322</link>
      <description>ITAT Kolkata allowed the appeal in favor of the assessee on multiple grounds. The tribunal excluded two comparables (Tata Elexi Limited and Sasken Technologies Ltd.) from TP analysis, reducing the average margin to 11.66% and bringing the assessee&#039;s 9.44% margin within the acceptable 3% range, eliminating TP adjustment requirements. TP adjustments for intra-group services and advertisement expenses were deleted based on previous favorable decisions. Section 14A disallowance was removed as no exempt income was earned. Double addition under section 41(1) was corrected, and lease rental disallowance was deleted following precedent. Section 80G deduction was allowed for CSR contributions.</description>
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      <pubDate>Tue, 11 Mar 2025 00:00:00 +0530</pubDate>
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