Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
The ITAT affirms the CIT(A)'s deletions and dismisses the Revenue's appeals. The Tribunal holds that for deduction computation under s.80IA(8) the market value of captive power consumed is the rate at which the assessee purchases electricity from the distribution company, and transfer pricing provisions do not override s.80IA(8) where no international transaction or real income element exists; the Explanation inserted in 2012 does not alter this position. Separately, the Tribunal upholds deletion of a s.40(a)(ia) disallowance for commissions paid to non-resident agents, concluding the services were rendered outside India, no income accrued in India, s.195 was not attracted and procedural compliance under s.195(6) was met.
The ITAT affirms the CIT(A)'s deletions and dismisses the Revenue's appeals. The Tribunal holds that for deduction computation under s.80IA(8) the market value of captive power consumed is the rate at which the assessee purchases electricity from the distribution company, and transfer pricing provisions do not override s.80IA(8) where no international transaction or real income element exists; the Explanation inserted in 2012 does not alter this position. Separately, the Tribunal upholds deletion of a s.40(a)(ia) disallowance for commissions paid to non-resident agents, concluding the services were rendered outside India, no income accrued in India, s.195 was not attracted and procedural compliance under s.195(6) was met.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
