Income Tax Appeal Partially Allowed: Section 14A Restriction, Depreciation Adjustment, and Loss Set-Off Provisions Clarified

ITAT partially allowed assessee's appeal for AY 2010-11. The tribunal directed the AO to: (1) restrict disallowance under Section 14A to exempt income earned, (2) recompute relief under Sections 10A/10AA consequent to disallowance, (3) uphold disallowance for software AMC payments from Germany and Austria, (4) allow set-off of losses incurred by units under Section 10AA against taxable profits, (5) grant 60% depreciation on computer software, and (6) delete addition of unrealized gains on unsold mutual fund units. The CIT(A)'s order was largely upheld, with specific directions for computational adjustments in the assessment. .....

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