https://www.taxtmi.com/caselaws?id=777077 ITAT DELHI - AT held that CUP could be applied only to four small export transactions and TNMM was the most appropriate method for the remaining international sales; order of CIT(A) was fortified. Sundry amounts written back were held to be income linked to export profits and deductible under s.80HHC. Depreciation disallowance based on retrospective reading of s.43A was reversed. Doubtful debts written off were allowed subject to proof of write-off in audited books. 60% depreciation on the software appliance was allowed and software-related expenses treated revenue in nature. Sales-tax incentives were disallowed in proceedings under s.148 (merits to be decided elsewhere) and treated as revenue receipts. MAT computation must grant full s.80HHC deduction based on books. Rule 8D disallowance under s.14A was improper; wind-mill depreciation allowed at 40%. Commission payments/TDS and cessation of liability issues were restored to AO for fresh examination. en-us Wed, 16 Jul 2025 00:00:00 +0530 Thu, 21 Aug 2025 15:41:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777077 ITAT DELHI - AT held that CUP could be applied only to four small export transactions and TNMM was the most appropriate method for the remaining international sales; order of CIT(A) was fortified. Sundry amounts written back were held to be income linked to export profits and deductible under s.80HHC. Depreciation disallowance based on retrospective reading of s.43A was reversed. Doubtful debts written off were allowed subject to proof of write-off in audited books. 60% depreciation on the software appliance was allowed and software-related expenses treated revenue in nature. Sales-tax incentives were disallowed in proceedings under s.148 (merits to be decided elsewhere) and treated as revenue receipts. MAT computation must grant full s.80HHC deduction based on books. Rule 8D disallowance under s.14A was improper; wind-mill depreciation allowed at 40%. Commission payments/TDS and cessation of liability issues were restored to AO for fresh examination. Case-Laws Income Tax Wed, 16 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777077