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    <title>2024 (2) TMI 1621 - ITAT CHENNAI</title>
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    <description>Deemed brand development TP adjustment was impermissible because the issue was consistently decided in earlier years and the TPO/DRP&#039;s approach to impute brand services was rejected; deletion of the adjustment was directed. Disallowance under s.14A had to be confined to the quantum of exempt income, as per settled Tribunal view; the AO was directed to restrict disallowance accordingly and make no disallowance if no exempt income arose. Export incentives under the Focus Market Scheme/MEIS were taxable as income under s.2(24)(xviii) (post-amendment) since the subsidy was not reduced from actual cost under Expln.10 to s.43(1); the claim was rejected. Depreciation reduction on capital subsidy was disallowed, following prior years; assessee&#039;s claim was allowed. Investment promotion/VAT subsidy was held taxable as income under the widened, substantive definition in s.2(24) read with s.5; addition was sustained.</description>
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    <pubDate>Fri, 09 Feb 2024 00:00:00 +0530</pubDate>
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      <title>2024 (2) TMI 1621 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=465857</link>
      <description>Deemed brand development TP adjustment was impermissible because the issue was consistently decided in earlier years and the TPO/DRP&#039;s approach to impute brand services was rejected; deletion of the adjustment was directed. Disallowance under s.14A had to be confined to the quantum of exempt income, as per settled Tribunal view; the AO was directed to restrict disallowance accordingly and make no disallowance if no exempt income arose. Export incentives under the Focus Market Scheme/MEIS were taxable as income under s.2(24)(xviii) (post-amendment) since the subsidy was not reduced from actual cost under Expln.10 to s.43(1); the claim was rejected. Depreciation reduction on capital subsidy was disallowed, following prior years; assessee&#039;s claim was allowed. Investment promotion/VAT subsidy was held taxable as income under the widened, substantive definition in s.2(24) read with s.5; addition was sustained.</description>
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