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2014 (1) TMI 1024 - AT - Income TaxEligibilty for deduction under Section 10B - Held that:- The benefit, if available to the assessee under the provisions of law, cannot be denied, simply on the basis of that assessee has taken contradictory stand before the AO and CIT(A) - The documents submitted by the assessee suggest that what was submitted by the assessee before the CIT(A), was the correct position - The facts can be verified from the documents filed by the assessee - The issue has been restored for fresh adjudication. Upward adjustment to the arms-length price - Held that:- The assessee has renedered bank guarantee to its associated enterprise - The evaluation was done by the TPO on the basis of comparables and figures given by the assessee - The average rate of 2.08% was taken and the assessee could not point out any defect - Decided against assessee. Disallowance u/s 14A - Held that:- Following M/s. Godrej and Boyce Manufacturing Co.Ltd. vs DCIT [2010 (8) TMI 77 - BOMBAY HIGH COURT] - The said rule 8D was not applicable in respect of assessment year 2007-08 - The CIT(A) calculated the disallowance on reasonable basus which was not disputed by the DR - Decided against Revenue.
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