Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
ITAT held that the Pr. CIT's revision under section 263, invoking Explanation 2 clause (a) to contend that CSR outlays mandated by the Companies Act, 2013 cannot form the source of donations eligible for deduction under section 80G, was unsustainable. The Tribunal found the issue settled by its coordinate benches that donations made from CSR-mandated funds may qualify for deduction under section 80G if all statutory conditions of section 80G are satisfied. Consequently, the initiation and sustaining of revisionary proceedings were based on a misconstruction of law; the order passed under section 263 was quashed and the assessee's grounds of appeal were allowed.
ITAT held that the Pr. CIT's revision under section 263, invoking Explanation 2 clause (a) to contend that CSR outlays mandated by the Companies Act, 2013 cannot form the source of donations eligible for deduction under section 80G, was unsustainable. The Tribunal found the issue settled by its coordinate benches that donations made from CSR-mandated funds may qualify for deduction under section 80G if all statutory conditions of section 80G are satisfied. Consequently, the initiation and sustaining of revisionary proceedings were based on a misconstruction of law; the order passed under section 263 was quashed and the assessee's grounds of appeal were allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
