Deduction u/s 80HHE is allowed against gross total income

DCIT Vs Zensar Technologies Ltd (ITAT Mumbai) ITAT Mumbai held that deduction under section 80HHE of the Income Tax Act is allowed against the gross total income. Facts- The return was selected for scrutiny and the notice u/s. 143(2) was served on the assessee. Since the assessee had international transaction, a reference was made to the Transfer Pricing Officer (TPO). The TPO made a Transfer Pricing Adjustment of Rs,22,88,380/-, towards salary cost of employees who are seconded to the US Associated Enterprise (AE). AO while passing the assessment order made disallowance towards Non compete Fe...