Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Disallowance u/s 14A read with Rule 8D - Assessing Officer did not record objective satisfaction for not accepting suo moto disallowance made by assessee. ITAT directed Assessing Officer to accept suo moto disallowance made u/r 8D(2)(iii) read with Section 14A. Only investments not yielding exempt income should be considered for disallowance u/s 14A read with Rule 8D. Deduction u/s 80G for donations - Deduction allowable for sums paid as donation. Donations to specific Kosh and Fund not allowable u/s 80G(2)(a)(iiihk) and (iiihl). Amounts spent on CSR activities u/s 135 of Companies Act 2013 not allowable as deduction u/s 80G. Disallowance for deduction u/s 80G vis-a-vis CSR restricted to contributions to these Funds under CSR. No error in allowing deduction claimed u/s 80G, except for contributions to these two funds.
Disallowance u/s 14A read with Rule 8D - Assessing Officer did not record objective satisfaction for not accepting suo moto disallowance made by assessee. ITAT directed Assessing Officer to accept suo moto disallowance made u/r 8D(2)(iii) read with Section 14A. Only investments not yielding exempt income should be considered for disallowance u/s 14A read with Rule 8D. Deduction u/s 80G for donations - Deduction allowable for sums paid as donation. Donations to specific Kosh and Fund not allowable u/s 80G(2)(a)(iiihk) and (iiihl). Amounts spent on CSR activities u/s 135 of Companies Act 2013 not allowable as deduction u/s 80G. Disallowance for deduction u/s 80G vis-a-vis CSR restricted to contributions to these Funds under CSR. No error in allowing deduction claimed u/s 80G, except for contributions to these two funds.
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