Transfer pricing CUP limited; TNMM accepted for remaining sales; s.80HHC export deductions allowed; s.43A depreciation rejected

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....ITAT affirmed that transfer pricing adjustment using CUP is permissible only for limited transactions (benchmarked at Rs.6.94 lakh) and upheld the assessee's use of TNMM for the remaining international sales (≈Rs.15.68 crore). Sundry amounts written back were held to form part of export profits and allowed for deduction under s.80HHC. Reliance on s.43A for denying depreciation was rejected and relief granted. Doubtful debts written off were allowed subject to audited book evidence of actual write-off. 60% depreciation on the software appliance and revenue treatment for software expenses were allowed. Sales-tax incentives could not be claimed in s.148 proceedings; merits reserved, but incentives held revenue in nature. MAT computation: ful.........