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    <title>2024 (9) TMI 1737 - ITAT CHENNAI</title>
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    <description>Weighted deduction for approved in-house R&amp;D expenditure could not be curtailed merely because DSIR had not quantified the full amount in Form 3CL before the amendment to Rule 6(7A), so the section 35(2AB) restriction was deleted. Software licence payments were not disallowed under section 40(a)(i) on the basis of a later retrospective royalty amendment, as a taxpayer cannot be expected to comply with an unanticipated deeming fiction. Disallowance under section 14A read with Rule 8D could not be imported into book-profit computation under section 115JB, since only permitted adjustments under that provision apply. Aircraft depreciation and related expenditure were remanded for reconsideration, while UPS depreciation at 60% was upheld as computer-related equipment.</description>
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    <pubDate>Wed, 25 Sep 2024 00:00:00 +0530</pubDate>
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      <title>2024 (9) TMI 1737 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=461948</link>
      <description>Weighted deduction for approved in-house R&amp;D expenditure could not be curtailed merely because DSIR had not quantified the full amount in Form 3CL before the amendment to Rule 6(7A), so the section 35(2AB) restriction was deleted. Software licence payments were not disallowed under section 40(a)(i) on the basis of a later retrospective royalty amendment, as a taxpayer cannot be expected to comply with an unanticipated deeming fiction. Disallowance under section 14A read with Rule 8D could not be imported into book-profit computation under section 115JB, since only permitted adjustments under that provision apply. Aircraft depreciation and related expenditure were remanded for reconsideration, while UPS depreciation at 60% was upheld as computer-related equipment.</description>
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      <pubDate>Wed, 25 Sep 2024 00:00:00 +0530</pubDate>
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