https://www.taxtmi.com/caselaws?id=461787 ITAT Bangalore ruled in favor of the assessee on multiple grounds. The tribunal held that software development constitutes an industrial undertaking engaged in production under Section 80JJAA, allowing deduction claims. The 300-day employment requirement was interpreted cumulatively across assessment years following Karnataka HC precedent. Additional depreciation on computers used for software production was allowed under Section 32(1)(iia). Transfer pricing adjustments were partially remanded, excluding high-turnover comparables exceeding Rs. 200 crores. The tribunal dismissed revenue's appeal on comparable company exclusions and provision for doubtful debts, while remanding corporate dividend tax and maintenance charges issues to AO for fresh adjudication. en-us Mon, 09 Dec 2024 00:00:00 +0530 Sat, 26 Apr 2025 11:31:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461787 ITAT Bangalore ruled in favor of the assessee on multiple grounds. The tribunal held that software development constitutes an industrial undertaking engaged in production under Section 80JJAA, allowing deduction claims. The 300-day employment requirement was interpreted cumulatively across assessment years following Karnataka HC precedent. Additional depreciation on computers used for software production was allowed under Section 32(1)(iia). Transfer pricing adjustments were partially remanded, excluding high-turnover comparables exceeding Rs. 200 crores. The tribunal dismissed revenue's appeal on comparable company exclusions and provision for doubtful debts, while remanding corporate dividend tax and maintenance charges issues to AO for fresh adjudication. Case-Laws Income Tax Mon, 09 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461787