9911796707
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Issues involved: Transfer Pricing Officer's order not filed, substantial questions of law framed regarding comparables for Rule 10D, eligibility for deduction under Section 10A, interest on housing loan deduction under Section 10B, nature of compensation received, rate of depreciation on computer peripherals, interest paid on income tax refund.
Transfer Pricing Officer's Order: Appellant directed to file the order within 3 weeks, failing which costs of Rs. 10,000 to be paid for delay. Order necessary to decide raised questions/issues. Substantial Question (i): Test and parameters for declaring comparables under Rule 10D, tribunal's findings on inclusion/exclusion legality to be examined. Substantial Question (ii): Eligibility of AEGSC (STP) unit for deduction under Section 10A of Income Tax Act, 1961 to be determined. Substantial Question (iii): Whether interest on housing loan for employees qualifies for deduction under Section 10B of Income Tax Act, 1961. Substantial Question (iv): Nature of Rs. 1,62,60,000 received as compensation from landlord - whether revenue receipt. Rate of Depreciation and Interest on Tax Refund: No substantial questions framed on rate of depreciation for computer peripherals due to precedent against Revenue. Similarly, no question on interest paid on income tax refund as it was decided in favor of Revenue. Document Filing: Printed paper books dispensation granted, parties allowed to file relevant documents/papers submitted before authorities/tribunal. Clarity and Efficiency: Emphasis on answering substantial question (i) promptly to prevent repetitive appeals and ensure clarity in similar cases. Listing: Case to be included in "Regular List (Part-IIA)" starting from the week of 24th February, 2014 for further proceedings.
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