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    <title>2024 (10) TMI 1681 - ITAT DELHI</title>
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    <description>Business receipts treated as income of the eligible undertaking, including interest on fixed deposits, corporate deposits and employee loans, foreign exchange gain, customer discount and computer-peripheral depreciation, were held includible for deduction under sections 10A and 10AA. Cost recoveries from sister concerns on a cost-to-cost basis were allowed to be apportioned, with 95% set off against eligible-unit expenses. Receipts excluded from export turnover were required to be excluded from total turnover to preserve parity in the section 10A formula. Payments for purchase of shares from Mauritius entities did not attract withholding tax under the India-Mauritius DTAA, so disallowance under section 40(a)(i) was not sustainable.</description>
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