Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
A donation to the Prime Minister's National Relief Fund made out of CSR expenditure remained eligible for deduction under section 80G, because the disallowance of CSR under Explanation 2 to section 37(1) operates only in computing business income, while Chapter VI-A deductions apply independently to gross total income. The Tribunal held that there was no statutory bar to claiming the section 80G deduction once the payment was made to an approved fund and the statutory conditions were met. The objection based on absence of voluntariness was rejected, as the assessee's choice of recipient was sufficient. The disallowance was deleted.
A donation to the Prime Minister's National Relief Fund made out of CSR expenditure remained eligible for deduction under section 80G, because the disallowance of CSR under Explanation 2 to section 37(1) operates only in computing business income, while Chapter VI-A deductions apply independently to gross total income. The Tribunal held that there was no statutory bar to claiming the section 80G deduction once the payment was made to an approved fund and the statutory conditions were met. The objection based on absence of voluntariness was rejected, as the assessee's choice of recipient was sufficient. The disallowance was deleted.
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