Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Disallowance u/s 80P - claim disallowed u/sec. 143(1)(a)(ii) by way of “processing” as an instance of “incorrect claim if such incorrect claim is there from any information in the return” - ITAT noted that this provision was applicable prospectively from April 1, 2021, while the assessment year in question was 2019-2020. Thus, the Tribunal concluded that this provision could not be applied retroactively to disallow the assessee’s deduction claim. - Relying on the principle of stricter interpretation as established in Commissioner vs. Dilip Kumar And Co. & Ors., the Tribunal concluded that the disallowance of the deduction claim by the lower authorities was not justified.
Disallowance u/s 80P - claim disallowed u/sec. 143(1)(a)(ii) by way of “processing” as an instance of “incorrect claim if such incorrect claim is there from any information in the return” - ITAT noted that this provision was applicable prospectively from April 1, 2021, while the assessment year in question was 2019-2020. Thus, the Tribunal concluded that this provision could not be applied retroactively to disallow the assessee’s deduction claim. - Relying on the principle of stricter interpretation as established in Commissioner vs. Dilip Kumar And Co. & Ors., the Tribunal concluded that the disallowance of the deduction claim by the lower authorities was not justified.
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