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    <title>2005 (4) TMI 251 - ITAT BOMBAY-F</title>
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    <description>The Tribunal held that the assessee, engaged in recruiting and training software professionals, was not entitled to exemption under Section 10B as its activities did not involve software production. The claim for deduction under Section 80HHE was denied due to lack of evidence of providing technical services. The CBDT notification on computer-enabled services was not retrospective. The Tribunal rejected netting off interest and upheld treating interest income as business income. The exclusion of 90% of interest for Section 80HHE was upheld. As the business income was not exempt under Section 10B, interest exemption did not apply. Consequential interest issues were directed for recomputation. The assessee&#039;s appeals were dismissed, and Revenue&#039;s partly allowed, emphasizing strict interpretation of tax laws.</description>
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    <pubDate>Thu, 07 Apr 2005 00:00:00 +0530</pubDate>
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      <title>2005 (4) TMI 251 - ITAT BOMBAY-F</title>
      <link>https://www.taxtmi.com/caselaws?id=59442</link>
      <description>The Tribunal held that the assessee, engaged in recruiting and training software professionals, was not entitled to exemption under Section 10B as its activities did not involve software production. The claim for deduction under Section 80HHE was denied due to lack of evidence of providing technical services. The CBDT notification on computer-enabled services was not retrospective. The Tribunal rejected netting off interest and upheld treating interest income as business income. The exclusion of 90% of interest for Section 80HHE was upheld. As the business income was not exempt under Section 10B, interest exemption did not apply. Consequential interest issues were directed for recomputation. The assessee&#039;s appeals were dismissed, and Revenue&#039;s partly allowed, emphasizing strict interpretation of tax laws.</description>
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      <pubDate>Thu, 07 Apr 2005 00:00:00 +0530</pubDate>
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