https://www.taxtmi.com/caselaws?id=783676 Computational errors in assessment were held rectifiable as apparent from record because deduction u/s 80-IA was fully denied despite an overlapping TP addition causing double disallowance, Chapter VI-A deduction and MAT credit were wrongly computed, and income was taken from intimation u/s 143(1) instead of the revised return; AO was directed to correct computations, recompute demand, and grant consequential refund. For TP on management support services, functionally dissimilar comparables (including a Government undertaking and a credit rating entity) were excluded, rendering the margin at arm's length; TP adjustment was deleted. Reimbursements of software costs received at cost were held not to require mark-up; adjustment was directed to be deleted. Captive power transfer ALP was held benchmarkable at SEB rate, not IEX; related adjustment was deleted. Disallowance u/s 14A without exempt income and corresponding MAT addition were held impermissible; deleted. Enhanced u/s 80-IA claim and trade-receivables adjustment were remitted for verification. Deduction u/s 35(2AB) could not be denied solely for non-issuance/delay of Form 3CL; AO directed to obtain it and allow as per law. en-us Fri, 12 Dec 2025 00:00:00 +0530 Tue, 16 Dec 2025 17:38:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783676 Computational errors in assessment were held rectifiable as apparent from record because deduction u/s 80-IA was fully denied despite an overlapping TP addition causing double disallowance, Chapter VI-A deduction and MAT credit were wrongly computed, and income was taken from intimation u/s 143(1) instead of the revised return; AO was directed to correct computations, recompute demand, and grant consequential refund. For TP on management support services, functionally dissimilar comparables (including a Government undertaking and a credit rating entity) were excluded, rendering the margin at arm's length; TP adjustment was deleted. Reimbursements of software costs received at cost were held not to require mark-up; adjustment was directed to be deleted. Captive power transfer ALP was held benchmarkable at SEB rate, not IEX; related adjustment was deleted. Disallowance u/s 14A without exempt income and corresponding MAT addition were held impermissible; deleted. Enhanced u/s 80-IA claim and trade-receivables adjustment were remitted for verification. Deduction u/s 35(2AB) could not be denied solely for non-issuance/delay of Form 3CL; AO directed to obtain it and allow as per law. Case-Laws Income Tax Fri, 12 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783676