Input tax credit conditions remain constitutionally valid, with eligible recipient claims considered under GST circulars and retrospective filing dead...
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...
The ITAT allowed the assessee's grounds regarding TP adjustment for interest on outstanding receivables from AEs and deduction u/s 35DD. It held that no separate interest on receivables is required to be imputed as the assessee is a debt-free company and working capital adjustment was granted, relying on the decisions in Boeing India and Kusum Health Care. On deduction u/s 35DD, it directed the AO to allow 1/5th of amalgamation expenditure based on the Supreme Court's decision in Goetze India. The ITAT also held that interest u/s 234B is consequential, and u/s 234C should be charged only on returned income, not assessed income.
The ITAT allowed the assessee's grounds regarding TP adjustment for interest on outstanding receivables from AEs and deduction u/s 35DD. It held that no separate interest on receivables is required to be imputed as the assessee is a debt-free company and working capital adjustment was granted, relying on the decisions in Boeing India and Kusum Health Care. On deduction u/s 35DD, it directed the AO to allow 1/5th of amalgamation expenditure based on the Supreme Court's decision in Goetze India. The ITAT also held that interest u/s 234B is consequential, and u/s 234C should be charged only on returned income, not assessed income.
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