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    <title>Assessee Wins Major Victory with Comprehensive Challenges to Disallowances and TDS Provisions &amp;DExpenditure</title>
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    <description>ITAT ruled in favor of the assessee, comprehensively addressing multiple taxation issues. The tribunal deleted disallowances under section 14A and section 115JB, finding no legal foundation for the Assessing Officer&#039;s additions. The tribunal accepted the assessee&#039;s R&amp;D expenditure claim under section 35(1)(iv), allowing deduction for capital expenditure in the approved scientific research facility. For TDS under section 195, the tribunal held that testing services by non-resident vendors did not constitute taxable income in India, as services were purely certification-based, did not transfer technical knowledge, and were utilized for export transactions. Consequently, the tribunal directed deletion of TDS-related disallowances and provided substantial relief to the assessee across multiple taxation grounds.</description>
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    <pubDate>Mon, 12 May 2025 09:01:10 +0530</pubDate>
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      <title>Assessee Wins Major Victory with Comprehensive Challenges to Disallowances and TDS Provisions &amp;DExpenditure</title>
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      <description>ITAT ruled in favor of the assessee, comprehensively addressing multiple taxation issues. The tribunal deleted disallowances under section 14A and section 115JB, finding no legal foundation for the Assessing Officer&#039;s additions. The tribunal accepted the assessee&#039;s R&amp;D expenditure claim under section 35(1)(iv), allowing deduction for capital expenditure in the approved scientific research facility. For TDS under section 195, the tribunal held that testing services by non-resident vendors did not constitute taxable income in India, as services were purely certification-based, did not transfer technical knowledge, and were utilized for export transactions. Consequently, the tribunal directed deletion of TDS-related disallowances and provided substantial relief to the assessee across multiple taxation grounds.</description>
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