Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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The ITAT Delhi ruled on denial of deduction u/s 80G for donations made as part of CSR expenditure. The appellant suo-motu disallowed the donations u/s 37(1). The tribunal held that CSR expenditure is part of the assessee's income and does not correlate with deduction u/s 80G. CSR donations are voluntary as they lack reciprocal promise. The Act allows deduction u/s 80G even without reciprocity. The tribunal sustained the deduction under section 80G. Regarding TDS credit, the tribunal referred to a previous case where TDS credit was allowed in the same year as income accrual. As the income was taxed in the relevant year, the appellant rightly claimed TDS credit. The appeal of the assessee was allowed.
The ITAT Delhi ruled on denial of deduction u/s 80G for donations made as part of CSR expenditure. The appellant suo-motu disallowed the donations u/s 37(1). The tribunal held that CSR expenditure is part of the assessee's income and does not correlate with deduction u/s 80G. CSR donations are voluntary as they lack reciprocal promise. The Act allows deduction u/s 80G even without reciprocity. The tribunal sustained the deduction under section 80G. Regarding TDS credit, the tribunal referred to a previous case where TDS credit was allowed in the same year as income accrual. As the income was taxed in the relevant year, the appellant rightly claimed TDS credit. The appeal of the assessee was allowed.
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