Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
The Income Tax Appellate Tribunal held that the enhancement made by the Commissioner of Income Tax (Appeals) was incorrect. The Assessing Officer was directed to delete the impugned additions. The Tribunal opined that the loss from one eligible industrial undertaking need not necessarily be adjusted against the profits from another eligible industrial undertaking for the purpose of deduction u/s 80IB. The decision in Synco Industries Limited was distinguished on facts as the issue there pertained to allowability of deductions under Chapter VIA when the gross total income was nil. Since the assessee had positive gross total income, it was eligible for deduction u/s 80IB without adjusting the losses of one unit against profits of another.
The Income Tax Appellate Tribunal held that the enhancement made by the Commissioner of Income Tax (Appeals) was incorrect. The Assessing Officer was directed to delete the impugned additions. The Tribunal opined that the loss from one eligible industrial undertaking need not necessarily be adjusted against the profits from another eligible industrial undertaking for the purpose of deduction u/s 80IB. The decision in Synco Industries Limited was distinguished on facts as the issue there pertained to allowability of deductions under Chapter VIA when the gross total income was nil. Since the assessee had positive gross total income, it was eligible for deduction u/s 80IB without adjusting the losses of one unit against profits of another.
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