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ITAT allowed the assessee's appeal in major respects. Disallowance under s.14A was deleted as the assessee had self-disallowed and requisite satisfaction was recorded; interest disallowance under Rule 8D(2)(ii) and administrative-cost disallowances were restricted to investments that actually earned exempt dividends. Weighted deduction under s.35(2AB) for the Rohtak unit was allowed. Provisional liabilities relating to FPI-OE components were deleted. Sharing of resources with group entities and CSR expenditure were allowed. Income from mutual funds/shares held as investment classified as capital gains, not business income. CBDT circular applied retrospectively. Additions under s.40(a)(i)/s.195 were deleted; certain excise/customs/PLA issues allowed or remitted per higher-court directions; royalty and R&D cess disallowances deleted.
ITAT allowed the assessee's appeal in major respects. Disallowance under s.14A was deleted as the assessee had self-disallowed and requisite satisfaction was recorded; interest disallowance under Rule 8D(2)(ii) and administrative-cost disallowances were restricted to investments that actually earned exempt dividends. Weighted deduction under s.35(2AB) for the Rohtak unit was allowed. Provisional liabilities relating to FPI-OE components were deleted. Sharing of resources with group entities and CSR expenditure were allowed. Income from mutual funds/shares held as investment classified as capital gains, not business income. CBDT circular applied retrospectively. Additions under s.40(a)(i)/s.195 were deleted; certain excise/customs/PLA issues allowed or remitted per higher-court directions; royalty and R&D cess disallowances deleted.
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