Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
The ITAT partly allowed the appeal of the assessee: for transfer pricing the AO is directed to adopt interest on outstanding receivables from AEs at LIBOR + 2% (TPO's LIBOR + 4% disallowed); corporate guarantee commission benchmarking limited to 0.5%; addition for alleged bogus purchases reduced and confirmed only to the actual transaction amount of Rs. 7,22,178 with directions to give effect. Claim for deduction under s.35(2AB) (R&D) is restored to the file of the AO for fresh adjudication in light of Form 3CL dated 20.08.2024. Donations from CSR funds are permitted for s.80G deduction subject to statutory eligibility and verification by the AO; matter remitted for fresh decision.
The ITAT partly allowed the appeal of the assessee: for transfer pricing the AO is directed to adopt interest on outstanding receivables from AEs at LIBOR + 2% (TPO's LIBOR + 4% disallowed); corporate guarantee commission benchmarking limited to 0.5%; addition for alleged bogus purchases reduced and confirmed only to the actual transaction amount of Rs. 7,22,178 with directions to give effect. Claim for deduction under s.35(2AB) (R&D) is restored to the file of the AO for fresh adjudication in light of Form 3CL dated 20.08.2024. Donations from CSR funds are permitted for s.80G deduction subject to statutory eligibility and verification by the AO; matter remitted for fresh decision.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
