Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The ITAT upheld the PCIT's revision under section 263, declaring the assessment order erroneous and prejudicial to revenue for failing to verify the deduction claim under section 80G. The matter was remitted to the AO with directions to verify receipts and eligibility of the donee before allowing the deduction. However, the Tribunal disagreed with the PCIT's disallowance of section 80G deduction relating to CSR expenditure, citing precedents affirming such claims cannot be denied. Consequently, the AO was directed to allow the section 80G deduction on CSR donations after proper verification. The assessee's appeal was partly allowed consistent with these findings.
The ITAT upheld the PCIT's revision under section 263, declaring the assessment order erroneous and prejudicial to revenue for failing to verify the deduction claim under section 80G. The matter was remitted to the AO with directions to verify receipts and eligibility of the donee before allowing the deduction. However, the Tribunal disagreed with the PCIT's disallowance of section 80G deduction relating to CSR expenditure, citing precedents affirming such claims cannot be denied. Consequently, the AO was directed to allow the section 80G deduction on CSR donations after proper verification. The assessee's appeal was partly allowed consistent with these findings.
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