https://www.taxtmi.com/caselaws?id=771300 ITAT Chennai partly allowed the appeal. Section 14A disallowance was restricted to investments generating exempt income only, not entire portfolio. AO directed to recompute consequential relief under sections 10A/10AA based on revised disallowance. TDS disallowance under section 40(a)(ia) for software AMC payments to Germany and Austria vendors upheld due to absence of 'make available' clause in DTAA. Software license payment disallowance deleted following SC precedent. Set-off of losses from units eligible for sections 10A/10AA against other taxable income allowed per Madras HC decision. Computer software depreciation allowed at 60% rate instead of 25%. Unrealized mutual fund gains addition deleted as units remained unsold. en-us Fri, 16 May 2025 00:00:00 +0530 Fri, 23 May 2025 08:46:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771300 ITAT Chennai partly allowed the appeal. Section 14A disallowance was restricted to investments generating exempt income only, not entire portfolio. AO directed to recompute consequential relief under sections 10A/10AA based on revised disallowance. TDS disallowance under section 40(a)(ia) for software AMC payments to Germany and Austria vendors upheld due to absence of 'make available' clause in DTAA. Software license payment disallowance deleted following SC precedent. Set-off of losses from units eligible for sections 10A/10AA against other taxable income allowed per Madras HC decision. Computer software depreciation allowed at 60% rate instead of 25%. Unrealized mutual fund gains addition deleted as units remained unsold. Case-Laws Income Tax Fri, 16 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771300