Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
