Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Objective characteristics and principal use govern mining-tyre classification, while fresh advance ruling applications may rely on additional technica...
Administrative fraud classification suspension does not halt independent criminal investigation or warrant-based searches into alleged economic offenc...
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The ITAT affirmed that the TPO's finding that specified domestic transactions (SDTs) were at arm's length precluded the AO from making independent ALP adjustments; the AO's selective adoption of the TPO's conclusions was held unsustainable and ground challenging ALP was dismissed. The Tribunal upheld the first appellate authority's application of Rule 8D(2) for section 14A disallowance and its exclusion of section 14A when computing book profits under section 115J. Claims for deduction under section 35(2AB), additional depreciation under section 32(1), and depreciation for prior-year foreign exchange loss were allowed. The AT admitted and upheld the assessee's contention that SHIS and fertilizer subsidy receipts are capital in nature.
The ITAT affirmed that the TPO's finding that specified domestic transactions (SDTs) were at arm's length precluded the AO from making independent ALP adjustments; the AO's selective adoption of the TPO's conclusions was held unsustainable and ground challenging ALP was dismissed. The Tribunal upheld the first appellate authority's application of Rule 8D(2) for section 14A disallowance and its exclusion of section 14A when computing book profits under section 115J. Claims for deduction under section 35(2AB), additional depreciation under section 32(1), and depreciation for prior-year foreign exchange loss were allowed. The AT admitted and upheld the assessee's contention that SHIS and fertilizer subsidy receipts are capital in nature.
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