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    <title>2026 (6) TMI 1024 - ITAT PUNE</title>
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    <description>Section 10AA deduction was upheld for the three undertakings of the amalgamated entity because the units had been accepted in earlier years and no contrary factual distinction was shown. Deduction was also allowed on profits from deputation of technical manpower and onsite software development, following the direct nexus recognised in the assessee&#039;s own case. Section 14A disallowance was deleted as no exempt income arose during the year. Depreciation on goodwill was allowed on written down value. Delisting expenses were not accepted as revenue expenditure for want of proof of business purpose, so that addition was restored. Foreign tax credit and deduction for Japan taxes were allowed in principle, while computation of credit and prior period expenses were remanded; interest allocation and MAT credit did not succeed for the assessee.</description>
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    <pubDate>Fri, 08 May 2026 00:00:00 +0530</pubDate>
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      <title>2026 (6) TMI 1024 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=793643</link>
      <description>Section 10AA deduction was upheld for the three undertakings of the amalgamated entity because the units had been accepted in earlier years and no contrary factual distinction was shown. Deduction was also allowed on profits from deputation of technical manpower and onsite software development, following the direct nexus recognised in the assessee&#039;s own case. Section 14A disallowance was deleted as no exempt income arose during the year. Depreciation on goodwill was allowed on written down value. Delisting expenses were not accepted as revenue expenditure for want of proof of business purpose, so that addition was restored. Foreign tax credit and deduction for Japan taxes were allowed in principle, while computation of credit and prior period expenses were remanded; interest allocation and MAT credit did not succeed for the assessee.</description>
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      <pubDate>Fri, 08 May 2026 00:00:00 +0530</pubDate>
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