https://www.taxtmi.com/caselaws?id=461954 ITAT Chennai allowed the assessee's appeal on multiple grounds. The tribunal permitted weighted deduction under section 35(2AB) for R&D expenditure, ruling that once DSIR approves the facility, expenditure automatically qualifies for deduction regardless of individual expenditure approval. Regarding forex loss in hedge reserve, deduction was allowed in the year charged to P&L account to prevent double disallowance. The tribunal held that section 14A disallowance cannot be applied while computing book profits under section 115JB, as it constitutes a separate code. For TDS under section 195, no disallowance was made for consultancy payments to UK, USA, and Singapore entities, as the services fell under respective tax treaty provisions for Independent Personal Services and did not meet the "make available test" criteria. en-us Wed, 25 Sep 2024 00:00:00 +0530 Sat, 10 May 2025 23:25:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461954 ITAT Chennai allowed the assessee's appeal on multiple grounds. The tribunal permitted weighted deduction under section 35(2AB) for R&D expenditure, ruling that once DSIR approves the facility, expenditure automatically qualifies for deduction regardless of individual expenditure approval. Regarding forex loss in hedge reserve, deduction was allowed in the year charged to P&L account to prevent double disallowance. The tribunal held that section 14A disallowance cannot be applied while computing book profits under section 115JB, as it constitutes a separate code. For TDS under section 195, no disallowance was made for consultancy payments to UK, USA, and Singapore entities, as the services fell under respective tax treaty provisions for Independent Personal Services and did not meet the "make available test" criteria. Case-Laws Income Tax Wed, 25 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461954