Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
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...
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ITAT Mumbai adjudicated multiple taxation issues, primarily focusing on disallowance under Section 14A, transfer pricing adjustments, and book profit calculations. The tribunal largely ruled in favor of the assessee, deleting disallowances related to notional interest expenditure and performance guarantees. Specifically, the ITAT held that no disallowance under Section 14A can be made without recorded officer satisfaction, and no transfer pricing adjustment is required for performance guarantees where no actual financial obligation exists. For book profit computation under Section 115JB, the tribunal restricted additional disallowances, following precedent that Rule 8D adjustments cannot be added while computing book profit. Both revenue's and assessee's appeals were ultimately allowed for statistical purposes, with key adjustments deleted or remanded.
ITAT Mumbai adjudicated multiple taxation issues, primarily focusing on disallowance under Section 14A, transfer pricing adjustments, and book profit calculations. The tribunal largely ruled in favor of the assessee, deleting disallowances related to notional interest expenditure and performance guarantees. Specifically, the ITAT held that no disallowance under Section 14A can be made without recorded officer satisfaction, and no transfer pricing adjustment is required for performance guarantees where no actual financial obligation exists. For book profit computation under Section 115JB, the tribunal restricted additional disallowances, following precedent that Rule 8D adjustments cannot be added while computing book profit. Both revenue's and assessee's appeals were ultimately allowed for statistical purposes, with key adjustments deleted or remanded.
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