Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The ITAT upheld the disallowance of deduction u/s 35(1)(ii) for donations related to scientific research due to raised donations based on forged documents. The Trust receiving donations was found ineligible as its approval had expired in 2006. The expenditure was disallowed as unexplained u/s 69C. The CIT(A) affirmed the disallowance as the appellant's claim was based on erroneous grounds. The appeal was dismissed, supporting the decision to disallow the deduction and highlighting the lack of eligibility of the entity for scientific research donations.
The ITAT upheld the disallowance of deduction u/s 35(1)(ii) for donations related to scientific research due to raised donations based on forged documents. The Trust receiving donations was found ineligible as its approval had expired in 2006. The expenditure was disallowed as unexplained u/s 69C. The CIT(A) affirmed the disallowance as the appellant's claim was based on erroneous grounds. The appeal was dismissed, supporting the decision to disallow the deduction and highlighting the lack of eligibility of the entity for scientific research donations.
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