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    <title>Ruling upholds TNMM royalty ALP, allows 10AA and 80JJAA despite delay, limits 14A for 115JB profits</title>
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    <description>Appeal by assessee was partly allowed. ITAT held that separate TP benchmarking for royalty was unwarranted when TNMM was accepted for other international transactions; assessee&#039;s TNMM-based ALP for royalty was upheld. Exemption u/s 10AA and deduction u/s 80JJAA, disallowed by CPC for a return filed a few hours late due to portal glitches, were sustained as valid, the due-date condition not being applicable for A.Y. 2018-19. Disallowance u/s 14A as made by AO was upheld, but ITAT directed that such disallowance not be added while computing book profits u/s 115JB. Deduction u/s 35(2AB), correction of double taxation of LTCG, and recomputation of interest u/s 234C were remitted to AO/JAO for verification and fresh computation.</description>
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    <pubDate>Wed, 10 Dec 2025 08:41:44 +0530</pubDate>
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      <title>Ruling upholds TNMM royalty ALP, allows 10AA and 80JJAA despite delay, limits 14A for 115JB profits</title>
      <link>https://www.taxtmi.com/highlights?id=94907</link>
      <description>Appeal by assessee was partly allowed. ITAT held that separate TP benchmarking for royalty was unwarranted when TNMM was accepted for other international transactions; assessee&#039;s TNMM-based ALP for royalty was upheld. Exemption u/s 10AA and deduction u/s 80JJAA, disallowed by CPC for a return filed a few hours late due to portal glitches, were sustained as valid, the due-date condition not being applicable for A.Y. 2018-19. Disallowance u/s 14A as made by AO was upheld, but ITAT directed that such disallowance not be added while computing book profits u/s 115JB. Deduction u/s 35(2AB), correction of double taxation of LTCG, and recomputation of interest u/s 234C were remitted to AO/JAO for verification and fresh computation.</description>
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      <pubDate>Wed, 10 Dec 2025 08:41:44 +0530</pubDate>
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