Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
TDS disallowance for professional fees paid to non-residents without TDS deduction was deleted as the payees did not have a fixed base or permanent establishment in India. Disallowance for payments to non-residents for services rendered outside India like VAT compliance, segregation charges for warehousing and delivery, advertisement expenses was deleted as the services did not constitute technical services and the non-residents had no permanent establishment in India. Expenditure towards corporate social responsibility was held allowable as revenue expenditure for the relevant years. Disallowance of interest on interest-free advances to a foundation was remitted back for verification of availability of interest-free funds. Disallowance u/s 80G was remitted back for verification of the donation certificate. Disallowance for market research expenses paid to a US entity was deleted as it did not constitute fees for technical services under the India-US tax treaty.
TDS disallowance for professional fees paid to non-residents without TDS deduction was deleted as the payees did not have a fixed base or permanent establishment in India. Disallowance for payments to non-residents for services rendered outside India like VAT compliance, segregation charges for warehousing and delivery, advertisement expenses was deleted as the services did not constitute technical services and the non-residents had no permanent establishment in India. Expenditure towards corporate social responsibility was held allowable as revenue expenditure for the relevant years. Disallowance of interest on interest-free advances to a foundation was remitted back for verification of availability of interest-free funds. Disallowance u/s 80G was remitted back for verification of the donation certificate. Disallowance for market research expenses paid to a US entity was deleted as it did not constitute fees for technical services under the India-US tax treaty.
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