Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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ITAT allowed Revenue's appeal and restored the disallowance of weighted deduction claimed u/s 35(1)(ii) by the assessee on donations made to a specified research institute. The Tribunal held that the donee institute did not have valid approval u/s 35(1)(ii) after 31.03.2006 and had procured donations on the basis of forged documents, rendering the assessee's claim impermissible in law. Relying on its earlier decision in a comparable case and the adverse findings of the Revenue, ITAT upheld the AO's action and quashed the order of CIT(A) which had granted relief to the assessee.
ITAT allowed Revenue's appeal and restored the disallowance of weighted deduction claimed u/s 35(1)(ii) by the assessee on donations made to a specified research institute. The Tribunal held that the donee institute did not have valid approval u/s 35(1)(ii) after 31.03.2006 and had procured donations on the basis of forged documents, rendering the assessee's claim impermissible in law. Relying on its earlier decision in a comparable case and the adverse findings of the Revenue, ITAT upheld the AO's action and quashed the order of CIT(A) which had granted relief to the assessee.
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