https://www.taxtmi.com/caselaws?id=464905 ITAT Mumbai allowed the assessee's claim for business development expenses as revenue expenditure, following its earlier decision in the assessee's own case, and upheld deduction u/s 10A for the STPI unit, agreeing with CIT(A) that a new eligible undertaking had commenced. Consequently, penalty u/s 271(1)(c) based on the disallowance of business development expenses was held unsustainable and deleted. ITAT further allowed the foreign exchange fluctuation loss as deductible u/s 37(1), applying the SC ruling in Woodward Governor. The disallowance u/s 14A r.w. Rule 8D(2)(iii) was sustained as correctly computed. On disallowance u/s 40(a)(ia), ITAT upheld CIT(A)'s deletion, holding that lower or incorrect TDS deduction does not trigger disallowance where tax has in fact been deducted. en-us Tue, 20 Mar 2018 00:00:00 +0530 Fri, 21 Nov 2025 14:03:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464905 ITAT Mumbai allowed the assessee's claim for business development expenses as revenue expenditure, following its earlier decision in the assessee's own case, and upheld deduction u/s 10A for the STPI unit, agreeing with CIT(A) that a new eligible undertaking had commenced. Consequently, penalty u/s 271(1)(c) based on the disallowance of business development expenses was held unsustainable and deleted. ITAT further allowed the foreign exchange fluctuation loss as deductible u/s 37(1), applying the SC ruling in Woodward Governor. The disallowance u/s 14A r.w. Rule 8D(2)(iii) was sustained as correctly computed. On disallowance u/s 40(a)(ia), ITAT upheld CIT(A)'s deletion, holding that lower or incorrect TDS deduction does not trigger disallowance where tax has in fact been deducted. Case-Laws Income Tax Tue, 20 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464905