Suo motu disallowance of expenses u/s. 40(a)(ia) could not amount to disallowance u/s. 37

INCOME TAX: Where Assessing Officer denied exemption under section 10AA to assessee-company on ground that relevant documents did not reveal any specific details regarding services rendered by assessee to its AEs and that these were in nature of software development activity, since TP adjustment proposed by TPO was in respect of payments received on account of services rendered by assessee under software development segment, assessee could not be denied exemption under said section on abovesaid

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