Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The ITAT reversed the CIT(A)'s confirmation of the AO's disallowance, directing allowance of deductions under sections 80P(2)(d) and 80P(2)(iv) of the Act. It held that deduction under section 80P(2)(d) for dividend and interest income from investments in cooperative societies is permissible on the gross amount, not net, distinguishing prior case law concerning business profits. The claim for deduction on profits from seed sales under section 80P(2)(iv) was upheld as per earlier ITAT decisions, allowing a 20% attribution of indirect expenses. Regarding section 14A read with Rule 8D disallowance for expenses incurred to earn exempt income, the tribunal ruled that such provisions do not apply to expenses related to income deductible under Chapter VIA. Consequently, the ITAT ruled entirely in favor of the assessee, directing the AO to grant the claimed deductions and delete the section 14A disallowance.
The ITAT reversed the CIT(A)'s confirmation of the AO's disallowance, directing allowance of deductions under sections 80P(2)(d) and 80P(2)(iv) of the Act. It held that deduction under section 80P(2)(d) for dividend and interest income from investments in cooperative societies is permissible on the gross amount, not net, distinguishing prior case law concerning business profits. The claim for deduction on profits from seed sales under section 80P(2)(iv) was upheld as per earlier ITAT decisions, allowing a 20% attribution of indirect expenses. Regarding section 14A read with Rule 8D disallowance for expenses incurred to earn exempt income, the tribunal ruled that such provisions do not apply to expenses related to income deductible under Chapter VIA. Consequently, the ITAT ruled entirely in favor of the assessee, directing the AO to grant the claimed deductions and delete the section 14A disallowance.
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