Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
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The ITAT allowed the assessee's appeal on the issue of disallowance of deduction u/s 80-IA. It held that the arm's length price for transfer of power from the captive power unit to the steel manufacturing unit should be the rate at which the State Electricity Board supplies power to industrial consumers, and not the rate at which it purchases power from suppliers. This is in line with the jurisdictional High Court's judgment in CIT v Godavari Power & Ispat Ltd and the Supreme Court's judgment in CIT v Jindal Steel and Power Ltd. Regarding the disallowance of deduction u/s 80G for donations, the ITAT restored the issue to the Assessing Officer for fresh adjudication after verifying whether the donations satisfied the conditions of section 80G. It also restored the connected issue of double disallowance of deduction u/s 80G to the Assessing Officer for re-adjudication.
The ITAT allowed the assessee's appeal on the issue of disallowance of deduction u/s 80-IA. It held that the arm's length price for transfer of power from the captive power unit to the steel manufacturing unit should be the rate at which the State Electricity Board supplies power to industrial consumers, and not the rate at which it purchases power from suppliers. This is in line with the jurisdictional High Court's judgment in CIT v Godavari Power & Ispat Ltd and the Supreme Court's judgment in CIT v Jindal Steel and Power Ltd. Regarding the disallowance of deduction u/s 80G for donations, the ITAT restored the issue to the Assessing Officer for fresh adjudication after verifying whether the donations satisfied the conditions of section 80G. It also restored the connected issue of double disallowance of deduction u/s 80G to the Assessing Officer for re-adjudication.
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