https://www.taxtmi.com/caselaws?id=770479 The ITAT Ahmedabad allowed the assessee's appeal on multiple grounds. The disallowance under section 14A and Rule 8D was deleted as the AO failed to record proper dissatisfaction with the assessee's suo motu disallowance computation. The consequent addition to book profits under section 115JB was also deleted, following judicial precedents that section 14A disallowances cannot be added to MAT calculations. Regarding section 35 deductions, the weighted deduction under section 35(2AB) was partially disallowed but alternative relief under section 35(1)(iv) at 100% was granted for genuine R&D capital expenditure. The TDS disallowance under section 40(a)(i) was deleted as testing services rendered abroad by non-residents did not constitute income accruing in India under section 9(1)(vii)(b) and relevant DTAAs. en-us Thu, 08 May 2025 00:00:00 +0530 Mon, 12 May 2025 09:01:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770479 The ITAT Ahmedabad allowed the assessee's appeal on multiple grounds. The disallowance under section 14A and Rule 8D was deleted as the AO failed to record proper dissatisfaction with the assessee's suo motu disallowance computation. The consequent addition to book profits under section 115JB was also deleted, following judicial precedents that section 14A disallowances cannot be added to MAT calculations. Regarding section 35 deductions, the weighted deduction under section 35(2AB) was partially disallowed but alternative relief under section 35(1)(iv) at 100% was granted for genuine R&D capital expenditure. The TDS disallowance under section 40(a)(i) was deleted as testing services rendered abroad by non-residents did not constitute income accruing in India under section 9(1)(vii)(b) and relevant DTAAs. Case-Laws Income Tax Thu, 08 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770479