Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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In the case before ITAT Chennai, the issue of disallowance u/s 14A r.w.r. 8D was considered. The CIT(A) found that no exempt income was earned by the assessee, leading to full relief being granted. The order of the CIT(A) and AO regarding disallowance was set aside, directing the AO to delete the addition from the total income. Regarding TDS u/s 195 for listing charges paid to Bank of New York, it was noted that DTAA provisions were not considered. The AO was directed to re-examine the issue in light of DTAA provisions. The claim of prior period expenditure was dismissed as it cannot be allowed in the assessment of a specific year. The writing off of carbon income was remanded to the AO for re-examination based on past treatment by the Department. The issue was decided in favor of the assessee for statistical purposes only.
In the case before ITAT Chennai, the issue of disallowance u/s 14A r.w.r. 8D was considered. The CIT(A) found that no exempt income was earned by the assessee, leading to full relief being granted. The order of the CIT(A) and AO regarding disallowance was set aside, directing the AO to delete the addition from the total income. Regarding TDS u/s 195 for listing charges paid to Bank of New York, it was noted that DTAA provisions were not considered. The AO was directed to re-examine the issue in light of DTAA provisions. The claim of prior period expenditure was dismissed as it cannot be allowed in the assessment of a specific year. The writing off of carbon income was remanded to the AO for re-examination based on past treatment by the Department. The issue was decided in favor of the assessee for statistical purposes only.
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