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    <title>Revenue appeal dismissed: &#039;arbitration award&#039; reclassified as software sale; forex gains exempt under s.10A; no s.40(a)(ia) disallowance</title>
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    <description>ITAT dismissed the Revenue&#039;s appeal and upheld the CIT(A)&#039;s orders: the amount characterized as an &quot;arbitration award&quot; was held to be a typographical misclassification of software sale and the related addition was deleted; foreign exchange fluctuation gains were held to be business receipts directly relatable to export of software and therefore eligible for exemption under s.10A; and no disallowance under s.40(a)(ia) was warranted where the assessee had deducted tax at source (albeit at a lower rate) on the buy-back consideration, such deduction being treated as compliance with the TDS obligation. The Revenue&#039;s challenge was therefore rejected in entirety.</description>
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    <pubDate>Tue, 07 Oct 2025 08:30:49 +0530</pubDate>
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      <title>Revenue appeal dismissed: &#039;arbitration award&#039; reclassified as software sale; forex gains exempt under s.10A; no s.40(a)(ia) disallowance</title>
      <link>https://www.taxtmi.com/highlights?id=93137</link>
      <description>ITAT dismissed the Revenue&#039;s appeal and upheld the CIT(A)&#039;s orders: the amount characterized as an &quot;arbitration award&quot; was held to be a typographical misclassification of software sale and the related addition was deleted; foreign exchange fluctuation gains were held to be business receipts directly relatable to export of software and therefore eligible for exemption under s.10A; and no disallowance under s.40(a)(ia) was warranted where the assessee had deducted tax at source (albeit at a lower rate) on the buy-back consideration, such deduction being treated as compliance with the TDS obligation. The Revenue&#039;s challenge was therefore rejected in entirety.</description>
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      <pubDate>Tue, 07 Oct 2025 08:30:49 +0530</pubDate>
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