SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
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The Delhi High Court addressed the issue of deduction u/s 11(1) concerning accumulation of 15% of deemed income. The court noted that Explanation 2, inserted by the Finance Act 2017, does not apply to the case at hand (AY 2009-10). The donations made by the respondent were not affected by Explanation 2 as they were not directed to specific institutions for corpus formation. The court explained that Section 11(2) allows for accumulation of income for charitable purposes. The donations made to other charitable institutions were not subject to adverse consequences u/s 11(3) as they were reversed within a short period. The court distinguished a previous case concerning Section 80T deductions, emphasizing the unique requirements of Section 11 for charitable institutions. The court ruled in favor of the assessee, rejecting the appellant's arguments.
The Delhi High Court addressed the issue of deduction u/s 11(1) concerning accumulation of 15% of deemed income. The court noted that Explanation 2, inserted by the Finance Act 2017, does not apply to the case at hand (AY 2009-10). The donations made by the respondent were not affected by Explanation 2 as they were not directed to specific institutions for corpus formation. The court explained that Section 11(2) allows for accumulation of income for charitable purposes. The donations made to other charitable institutions were not subject to adverse consequences u/s 11(3) as they were reversed within a short period. The court distinguished a previous case concerning Section 80T deductions, emphasizing the unique requirements of Section 11 for charitable institutions. The court ruled in favor of the assessee, rejecting the appellant's arguments.
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