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...
ITAT adjudicated multiple taxation issues: (1) Rejected transfer pricing adjustment on commission paid to local distributors, finding it not an AMP expense and consistent with prior assessment years. Tribunal set aside TPO/AO/DRP order and deleted the adjustment. (2) Allowed deduction under Section 80G for CSR contributions, holding that Explanation 2 to Section 37 cannot deny deductions for donations made by charitable trusts registered under 80G. (3) Remanded the 80G deduction claim back to AO for verification, directing assessee to submit donation receipts and substantiate eligibility conditions. The ITAT's rulings emphasized procedural fairness and consistent interpretation of tax provisions.
ITAT adjudicated multiple taxation issues: (1) Rejected transfer pricing adjustment on commission paid to local distributors, finding it not an AMP expense and consistent with prior assessment years. Tribunal set aside TPO/AO/DRP order and deleted the adjustment. (2) Allowed deduction under Section 80G for CSR contributions, holding that Explanation 2 to Section 37 cannot deny deductions for donations made by charitable trusts registered under 80G. (3) Remanded the 80G deduction claim back to AO for verification, directing assessee to submit donation receipts and substantiate eligibility conditions. The ITAT's rulings emphasized procedural fairness and consistent interpretation of tax provisions.
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