Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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The ITAT Delhi addressed various issues in the case. Firstly, regarding addition u/s 68 due to a difference in Form 26AS and income in the return, CIT(A) deleted the addition as the amount was already accounted for in a previous assessment year, attributing the discrepancy to an error by M/s Dharampal Satyapal Ltd. The Tribunal upheld this decision based on reconciliation presented. Secondly, disallowance u/s 37 on salary/wages was challenged, but CIT(A) found evidence of proper payments to employees and deleted the addition. Lastly, disallowance u/s 14A was not warranted as no exempt income was earned by the assessee, following the precedent set in Cheminvest Limited case.
The ITAT Delhi addressed various issues in the case. Firstly, regarding addition u/s 68 due to a difference in Form 26AS and income in the return, CIT(A) deleted the addition as the amount was already accounted for in a previous assessment year, attributing the discrepancy to an error by M/s Dharampal Satyapal Ltd. The Tribunal upheld this decision based on reconciliation presented. Secondly, disallowance u/s 37 on salary/wages was challenged, but CIT(A) found evidence of proper payments to employees and deleted the addition. Lastly, disallowance u/s 14A was not warranted as no exempt income was earned by the assessee, following the precedent set in Cheminvest Limited case.
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